Draft Decision Dkt No

STATE OF CONNECTICUT
DEPARTMENT OF PUBLIC UTILITY CONTROL
TEN FRANKLIN SQUARE
NEW BRITAIN, CT 06051
DOCKET NO. 02-06-12 DPUC IMPLEMENTATION OF A STATE-WIDE 311
NUMBER
December 16, 2002
By the following Commissioners:
Jack R. Goldberg
John W. Betkoski, III
Linda J. Kelly
DRAFT DECISION
TABLE OF CONTENTS
I. INTRODUCTION ...................................................................................................... 1
A. SPECIAL ACT NO. 02-16 ....................................................................................... 1
B. FEDERAL COMMUNICATIONS COMMISSION .............................................................. 1
II. OTHER CITIES AND STATES ................................................................................. 2
III. CONNECTICUT 311 SERVICE DIALING PLAN ...................................................... 3
A. CONNECTICUT 311 SERVICE .................................................................................. 3
B. CONNECTICUT 311 SERVICE DEMAND .................................................................... 5
C. CONNECTICUT 311 SERVICE NETWORK DESIGN ...................................................... 5
D. ESTIMATED COST OF CONNECTICUT 311 SERVICE .................................................. 6
E. CONNECTICUT 311 SERVICE FUNDING.................................................................... 9
F. CONNECTICUT 311 SERVICE IMPLEMENTATION........................................................ 9
1. Wireline ........................................................................................................ 9
2. Wireless ..................................................................................................... 10
G. ACCESS TO CONNECTICUT 311 SERVICE .............................................................. 12
H. EDUCATION PLAN ............................................................................................... 12
IV. CONCLUSION ........................................................................................................ 12
I. INTRODUCTION
A. SPECIAL ACT NO. 02-16
On June 13, 2002, Special Act No. 02-16, An Act Concerning a State-Wide 311
Number and a Reverse 911 Number (Act), was signed into law by Governor Rowland.
SA 02-16 required the Department of Public Utility Control (Department), within
available appropriations, in conjunction with the Department of Public Safety (DPS) and
Infoline of Connecticut (Infoline), to develop a plan (Plan) for the implementation of a
state-wide non-emergency governmental telecommunications service to be known as
311 service. The Department was required to submit its plan to the Legislature’s
Energy and Technology Committee no later than January 1, 2003. A copy of SA 02-16
is appended hereto as Attachment 1.
B. FEDERAL COMMUNICATIONS COMMISSION
By its February 19, 1997 order in CC Docket No. 92-105, In the Matter of The
Use of N11 Codes and Other Abbreviated Dialing Arrangements (N11 Order), First
Report and Order and Further Notice of Proposed Rulemaking, the Federal
Communications Commission (FCC) adopted an abbreviated dialing arrangement to
reach non-emergency police services by assigning 3111 on a nationwide basis for this
purpose.2 N11 Order, ¶ 2. A copy of the N11 Order is appended hereto as Attachment
2.
In the N11 Order, the FCC determined that the assignment of a national number
through which the public could gain access quickly to non-emergency police and other
government services was in the public interest.3 Id., ¶35. The FCC required that when
a provider of telecommunications services receives a request from an entity (e.g., a
local police chief or local fire chief) to use 311 for access to non-emergency police and
other government services in a particular jurisdiction, it must ensure that, within six
months of the request: (1) entities that were assigned 311 at the local level prior to the
effective date of the N11 Order relinquish non-compliant uses; and (2) it takes any steps
necessary (e.g., reprogramming switch software) to complete 311 calls from its
subscribers to a requesting 311 entity in its service area. Id.
1 311 Service was originally envisioned as a means for the public to contact law enforcement agencies in
non-emergency circumstances. However, in many jurisdictions, the public can gain access to both law
enforcement and other government agencies by dialing an all-purpose 7-digit non-emergency
telephone number. DGS Report to the Governor and Legislature: Non-Emergency Number Pilot
Programs, City of San Diego, City of San Jose (DGS Report), November 2000, p. 6.
2 Assignment means that a numbering plan administrator announces to the industry that a particular
number will be used for certain, defined services.
3 The FCC left to local jurisdictions the discretion to determine whether 311 should be used locally to
reach other government services. According to the FCC, local jurisdictions could better determine
whether this code could or should be used for access to services in addition to non-emergency police
services. The FCC also found that state public utilities commissions, in conjunction with state and
local governments, could address any conflicting requests for use of 311 (e.g., situations in which city
and county law enforcement agencies both request 311 implementation in the same geographic area)
better than the FCC. N11 Order, ¶37.
Docket No. 02-06-12 Page 2
The FCC also determined that use of an N11 code for access to non-emergency
police services could alleviate congestion on 911 circuits, which would permit more
effective operation of 911 emergency services. In the opinion of the FCC, by promoting
the safety of life and property and ensuring the public prompt access to emergency
services was consistent with the purpose of the Telecommunications Act of 1996
(Telcom Act). The FCC stated that in determining not to alter 911’s designation as a
national code for emergency services, serves the public interest because end users
would know that they can dial 911 from virtually any exchange in the country in order to
obtain emergency assistance. The FCC concluded that ensuring that 911 circuits are
not overburdened with non-emergency calls would let callers know that they can dial
911 from any exchange (to obtain necessary governmental services) without hampering
others’ access to 911 for emergencies. Id., ¶ 36.
The FCC states that 311 is being used in several jurisdictions. Id., ¶38. A
greater discussion of the use of 311 in other cities and states is presented below in
Section II. The FCC also permitted the states and local governments to deploy 311
through their 911 centers or devise alternative procedures for routing and answering
311 calls. The FCC acknowledges that a provider of telecommunications services may
incur certain costs (e.g., in reprogramming switch software) to enable implementation of
311. Since 311 calls, like 911 calls, are typically intrastate in nature, states would
regulate cost recovery in most instances. Funding of 311 service would also be a local
issue. Id., ¶42.
The wireless industry also expressed concern about costs and other
implementation issues in the FCC proceeding.4 In recognition of the issues and
problems associated with the wireless industry’s provision of 311, the FCC refrained
from imposing the same types of obligations on wireless providers with regard to 311
service as it did for 911 service. Id., ¶43.
II. OTHER CITIES AND STATES
The FCC has provided the states/local authorities with the ability to implement
311 dialing in their respective jurisdictions. While 311 dialing is not implemented on a
state-wide basis any where in the country, it is currently offered in 14 cities in the United
States. In particular, 311 non-emergency telephone service is provided in the cities of
Austin, Texas; Baltimore, Maryland; Bethel, Alaska; Chicago, Illinois; Columbia, South
Carolina; Dallas, Texas; Detroit, Michigan; Hampton, Virginia; Houston, Texas; Las
Vegas, Nevada; Rochester, New York; San Antonio, Texas; San Jose, California; and
Washington, DC.5 Additionally, although 311 has been designated as a non-emergency
service by the FCC, some of those cities have employed 311 dialing for other purposes.
4 The Department, in preparing this report, solicited comments from Verizon Wireless (VW) concerning
the deployment of 311 in Connecticut. A discussion of VW’s comments is presented in Section III.F.2.
5 Other cities and counties planning 311 Systems include: New York, New York; Philadelphia,
Pennsylvania; Calgary and Halifax, Canada; Suffolk County, New York; Los Angeles County,
California; Miami-Dade County, Florida; Howard County, Maryland; Lane County, Oregon; and
Broward County, Florida. Motorola Presentation, Overview of 311 and Customer Service Request
Systems for Government, Canadian Community Information & Referral Conference, Ottawa, Ontario,
November 14, 2002.
Docket No. 02-06-12 Page 3
For example, of the 14 cities where 311 dialing is available, seven cities6 have
employed the abbreviated dialing function for city service calls. 7 The remaining cities
have established 311 calling for non-emergency police incidents.8 Moreover, 311 calls
within these cities are answered either by police call takers, 311 call takers or in Dallas,
by fire department call takers.
In preparing the Plan, the Department contacted a number of cities where 311
dialing is currently offered.9 The Department notes that the population served by 311 in
these cities ranges from a low of 117,000 (Columbia, SC) to 3 million (Las Vegas, NV).
The annual number of 311 calls ranged from 237,000 (Hampton, VA) to 16 million
(Houston, TX). A copy of a table summarizing this information together with the number
of 311 support personnel and cost of providing 311 service by city is appended hereto
at Attachment 3.
III. CONNECTICUT 311 SERVICE DIALING PLAN
Connecticut 311 Service is a service that would be made available to local
governmental entities to provide its citizens with an easy to remember telephone
number for access to non-emergency government services. Connecticut 311 Service
would utilize the intelligent routing functionality of the public switched network to
complete 311 dialed calls to the appropriate 311 call center. The 311 call completion
would be based on the calling party’s geographic location within the subscribing
governmental entities’ geographic boundary. Call routing would be based on the
development of a database of citizen information related to their geographic location
and the telephone number that they are calling from.
A. CONNECTICUT 311 SERVICE
SA 02-16 requires the Department in conjunction with DPS and Infoline to
develop a plan for the implementation of a state-wide non-emergency governmental
telecommunications service to be known as 311 Service. As a preliminary step to the
Plan, the Department recommends that a determination be made to identify the non-
emergency services that would be accessed when 311 is dialed. For example, although
6 Chicago, Columbia, Dallas, Detroit, Hampton, Houston and San Antonio.
www.911dispatch.com/information/311map.html.
7 City service calls include, but are not limited to water, power, sanitation services, library books, and
recreation services. City of Los Angeles 311E Government Service Project, Project Overview, Price
Waterhouse Coopers, p. 17.
8 Non-emergency police incident calls include property crimes that are no longer in progress and the
offender is not on the scene. Non-emergency police incidents also include crimes such as vandalism,
thefts, graffiti, stolen automobiles and garage burglaries. Additionally, non-emergency police calls
include animal control problems; illegally parked vehicles; minor vehicle accidents where there are no
injuries and traffic is not blocked; and the phone numbers, addresses hours of operation, etc. of local
police units or programs. Washington DC Metropolitan Police Department Website,
http://mpdc.dc.gov/info/phone/311.shtm.
9 Between September 9, 2002 and October 14, 2002, the Department staff contacted 311 support
personnel querying them about the date 311 calling was first implemented, population served, cost
information, number of 311 support personnel, annual number of 311 calls received and the type of
311 center management.
Docket No. 02-06-12 Page 4
311 is currently offered in 14 cities throughout the United States, the types of services
offered in these jurisdictions is evenly mixed (i.e., abbreviated dialing access to city
services vs. non-emergency police calls). As an aid in making this determination, the
Department recommends that the DPS 911 calling statistics and Infoline calling volumes
be reviewed to determine the most appropriate use for the 311 Service.
During this proceeding, DPS provided 911 calling statistics measuring the
number of calls received at the state’s Public Safety Answering Points (PSAP) for the
period January through October 2002. A copy of those statistics are appended hereto
as Attachment 4.
Infoline also provided calling volumes for the health and human services
information and referrals that it offers in Connecticut for the years 2000 and 2001. A
copy of those statistics are appended hereto as Attachment 5. The Department notes
that in testimony proffered during public hearings concerning then Raised Bill 308,
Infoline indicated that it:
Already fields thousands of calls from residents looking for a myriad of
municipal government services including senior centers, youth activities,
public health inspections, tax assistance, assessors libraries, schools,
town administrative entities, etc. In addition, there are many more
thousands of requests for services provided by state agencies including
the department of Social Services, Children and Families, Mental Health
and Addiction Services, Public Health, Insurance, Consumer Protection,
Motor Vehicles, etc.10
Infoline also testified:
Infoline is able to refer callers to the appropriate agency and site where
service is located because of its extensive, constantly updated database
of resources and trained, professional staff who are skilled in assessment
techniques and knowledgeable about health and human service systems
in the state. The database contains information about 403 state and
municipal agencies with over 8000 sites where services are delivered.11
As the record of Raised Bill No. 308 indicates, Connecticut 911 PSAPs are not
being overburdened with non-emergency calls. In addition, based on the testimony of
Infoline official Melanie Loewenstein, a 311 non-emergency governmental
telecommunications system has the potential of duplicating the existing services offered
through Infoline 211. Id., pp. 1 and 2.
10 Testimony of Melanie Loewenstein, Senior Vice President of United Way of Connecticut, Raised Bill
No. 308; LCO No. 1469, dated February 26, 2002, p. 2.
11 Id.
Docket No. 02-06-12 Page 5
B. CONNECTICUT 311 SERVICE DEMAND
Before proceeding with the implementation of Connecticut 311, the Department
also recommends that a determination be made as to the types of services that would
be offered end users when dialing 311. For example, do Connecticut cities and towns
want 311 dialing as a means of responding to non-emergency calls that would normally
be transported to city/town PSAPs or municipal offices for local information? Would
cities/towns prefer Connecticut 311 Service to offer both non-emergency and city town
information? Based on the responses from those questions as well as an analysis of
the DPS 911 and Infoline 211 calling statistics, a better idea of how Connecticut 311
Service should be offered could be determined.
In addition, a demand/opinion survey of users (i.e., city/state residents,
businesses, etc.) should also be considered to determine the services that could be
delivered by Connecticut 311 Service. At that time, the public could also be queried
concerning their knowledge of 911 service, Infoline and the types of information
provided by dialing 211.
C. CONNECTICUT 311 SERVICE NETWORK DESIGN
After identifying the services that could be accessed by 311, the next step in
deploying Connecticut 311 Service is to identify and develop the appropriate network
design that 311 service would utilize. The Department believes that there are four
possible network design scenarios that Connecticut 311 Service could employ.12
For example, Connecticut 311 Service could adopt a scenario that mirrors the
state’s current 911 Public Safety Answering Point network wherein non-emergency calls
would be directed to the state’s PSAPs. Possible issues with this scenario however,
could result in non-emergency calls being directed to PSAPs placing a burden on
emergency dispatchers. It should be noted that if 311 calls are directed to a 911 PSAP,
the 311 call may not be answered quickly because 911 calls have priority. Another
issue that could occur would be in those cases where the calls would terminate in
regional centers, such calls could not directly connect the caller to municipal entity. 13
Nevertheless, if this scenario were adopted, one benefit would be that calling centers
(i.e., the PSAPs) are operational on a seven-day, 24 hour (7X24) basis.
A second scenario consists of a county-wide answering point. Under this
scenario, there would be no central governing body and/or support agencies. There
would most likely also be a limited community of interest in county-wide call centers.
Additionally, the calling center could operate as a regional non-emergency answering
point, but like the PSAP scenario, county-wide call centers could not directly connect
12 On September 18, 2002, members of the Department’s staff met with representatives of the Southern
New England Telephone Company (Telco) to discuss the 311 non-emergency service requirements
and the public switched network. By teleconference call on October 7, 2002, the Department also
discussed the implications of 311 non-emergency service with representatives of Cox Connecticut
Telcom, L.L.C.
13 It has been argued that the real problem is not an overload of non-emergency calls to the 911 system,
but rather, a shortage in 911 call takers and dispatchers. DGS Report, p. 10.
Docket No. 02-06-12 Page 6
callers to municipal entities. Lastly, county-wide call centers would not be able to
control multiple municipal out of hour messages.
Mirroring the current 211 answering point scenario is another possible network
design. This network design could provide a central answering point for statewide non-
emergency calls. However, similar to the previous scenarios, the call center would only
be able to connect the caller to a municipal entity at a significant additional cost. Finally,
if the 211 answering point scenario were adopted, it could follow the same hours of
operation as Infoline (i.e., 7X24).
Finally, Connecticut 311 Service could be deployed on a municipal answering
point basis. Under this scenario, the municipality would provide services directly to its
citizens. The municipal call center would also be in a position to connect callers to the
appropriate service entity. The municipality would also manage the hours of operations
as well as control its out of hours messages.
Telco 311 Service Outline, pp. 1 and 2.
D. ESTIMATED COST OF CONNECTICUT 311 SERVICE
Quantification of the cost of Connecticut 311 Service will depend on several
factors including the number of agencies participating; level of services provided by
those agencies; equipment, staffing and public relations costs; and the actual cost to
administer the Connecticut 311 Service. Additionally, an investigation and quantification
of the cost associated with 311 equipment must be undertaken. Based on the 311
network model that is eventually deployed, specific 311 call answering and call
management equipment must be identified and the underlying cost calculated to
correspond to that network design. Finally, the cost of public education and (both
announcing the deployment of Connecticut 311 Service as well as ongoing public
education) must be factored into the start-up and annual cost of offering the service in
the state.
Motorola indicates that the cost of a 311 service operation is made up of several
cost elements. Each element has many dimensions that must be defined before a clear
estimate of the total can be made. The following table illustrates the elements that need
to be considered by Connecticut in the evaluation of the 311 service project.14
Cost Category Cost Items Questions?
- Statewide or regional
- How many call
Architecture - Operational Concept centers
- System Design - How many
- Interfaces databases
- Any mandatory
interfaces
311 - State needs to
- Transaction Service Fee negotiate a favorable
Telecommunication
14 Motorola State of Connecticut 3-1-1 Initiative, December 5, 2002, pp. 2-4.
Docket No. 02-06-12 Page 7
Cost Category Cost Items Questions?
s Service Charges rate per 311 call with
telecommunications
provider
- Facilities & equipment (Build- - # of call centers
out, Maintenance, Utilities, - # of call takers
Call Center(s) Lease, desks, computers)
- Salaries (Managers,
Supervisors, Customer Service
Representatives)
- Use existing
Communications - WAN’s & LAN’s, T1 charges, infrastructure
Citizen web intake - What else needs to
be purchased
- Use existing
hardware
CSR Hardware - Servers, Routers
- What else needs to
be purchased
- # CSR concurrent
users
- How many mapping
licenses
CSR Software - Licenses, Maintenance
- How many mobile
laptop licenses
- How many mobile
handheld licenses
- How many service
request types to be
configured
- How many
configuration
managers to be
- Configuration trained
CSR Deployment - Training - How many CSR
- Dataloads trainers to be trained
- Interfaces - How many geodata
loads required
- How many different
GIS data sources to
be used
- What interfaces to
CSR must be
developed
- How does CT plan to
- Citizen Awareness Campaign educate the public on
Operations - Return on Investment Analysis use of 311
- How does CT plan to
measure ROI
Docket No. 02-06-12 Page 8
Motorola also states that its experience indicates that the major costs for a large
deployment as envisioned by Connecticut may lie in the following bands:15
 Telecommunications – $0.05 - $0.10 per 311 call (~$200,000/yr for 2 million
calls)
 75-person Call Center – $1 million to $3 million
 Customer Service Request (CSR) Hardware - $500,000
 CSR Licenses - $750,000
 CSR Deployment Services - $1 million
 Infrastructure upgrades (if needed) – TBD
 Software interfaces between CSR and legacy systems (if required) – TBD
 Recurring employee costs - TBD
In addition, Motorola16 indicates that its CSR System would offer participating
cities and towns the tools that managers need to communicate with citizens and the
departments that need to deliver services. Motorola’s claims that its CSR product is the
software utilized by many 311 service call center call takers to handle and respond to
the calls because it has been developed specifically for state and local government
service delivery needs. According to Motorola, the CSR product provides a knowledge
based where call takers can search using topics, keywords, or location information to
determine how to refer a call and forward it to the agency responsible for the call, if the
call center cannot resolve the call.17 Services that could be provided include: work
order management; links service requests, ability to link multiple requests to each other;
efficient alignment of manpower by supporting the dispatching of crews at the
designated time in the workflow process; correspondence management; on-line
information directory; and controls over the amount of information collected and used for
each service request by key staff.18
Moreover, the Telco suggests that Connecticut 311 Service components would
include the following:
 Local service required from the municipality central office for call completion.
This provides the called Route to Number (RTN). Municipality defined function
regarding call completion and non-emergency services would be covered.
 Single RTN within the municipal geographic boundary.
 Non-emergency 311 service database required to identify eligible callers and to
provide appropriate call routing information to the RTN. The 311 database will
require that all non-subscribing citizen end users be excluded.
15 Id., p. 4.
16 On November 8, 2002, the Department staff discussed with representatives of Motorola, its CSR
System. According to Motorola, the CSR system is a tool used by public enterprises to help them
maintain a high level of service delivery to their citizens. CSR System Brochure, p. 3.
17 Motorola State of Connecticut 3-1-1 Initiative, December 5, 2002, p. 1.
18 Motorola CSR Brochure, p. 3.
Docket No. 02-06-12 Page 9
 Multiple non-emergency 311 service databases are required when a central
office serves multiple municipalities. For example, one subscribing municipality
and one or more non-subscribing municipalities. The intelligent routing network
needs to be deployed in any additional central offices to cover subscribing citizen
end users.
 Coordinated implementation between the Telco and the municipality.
The Telco also suggests that the following non-emergency 311 service tariff
components would be incurred:
Recurring charges: Per System, Per Central Office, Per Call, or Budget Usage
Billing and an optional Call Summary Report;
Non-recurring charges: Per System Establishment, Per Central Office Equipped,
Per System Table Changes and Table Updates and optional Budget Billing Set
Up.
Therefore, a complete cost analysis of Connecticut 311 Service will have to be
conducted that identifies all components of the service and the associated cost.
E. CONNECTICUT 311 SERVICE FUNDING
While SA 02-16 has required the Department, DPS and Infoline to develop a plan
to implement state-wide 311 calling, the Act is silent as to how service implementation
will be funded. The Department will seek guidance from the Legislature as to how
Connecticut 311 Service should be funded.
F. CONNECTICUT 311 SERVICE IMPLEMENTATION
1. Wireline
SBC Communications, Inc. (SBC) currently provides 311 Non-Emergency
Service in Chicago, IL; San Jose, CA; Dallas, Houston and San Antonio Texas.
According to the Telco, SBC’s experience for a typical 311 system implementation has
ranged from 9 to 15 months. The Telco states that each interval is established based
on negotiations with each customer as to how they intend to operate the service and the
non-emergency agencies that would be covered by the service. The Telco also states
that the implementation interval has been affected by database vendor selection
processes and the level of deployment of intelligent network technology in each specific
area.19 The systems currently deployed by SBC equally serves police non-emergency
calls and both police and governmental agencies non-emergency calls. The Telco
claims that there is also a 50/50 split on stand alone 311 call centers vs. the 311 call
center function being integrated into existing 911 call centers in those cities.
19 The Telco indicates that the Chicago 311 system has 44 central offices (CO), the Los Angeles system
has 55 COs and the Houston system has 65. This compares to 130 COs that would most likely have
to be equipped for the offering of 311 service in Connecticut.
Docket No. 02-06-12 Page 10
Additionally, the Telco indicates that SBC’s experience has been that all sites handling
311 non-emergency calls are being manned 7X24.
2. Wireless
The wireless industry puts forward different issues that are not typically present
with those of the wireline community. By their very nature, wireless mobile services are
not associated with any particular community or political subdivision. From the
customer’s perspective, access to services such as those which might be available
through the assignment of a N11 code (in this case 311 service) to a community service
provider, is different in the mobile setting than it would be through landline access from
their homes or offices. Wireless operators have customers whose geographic locations
vary constantly. The customer’s mobile phone number is not an indicator of what
“community” the customer is located in at any given time, and often does not reflect the
“community” where the customer lives or works. There may be little correlation between
the phone number and any of the customer’s communities of interest. 20 Likewise, the
phone number may not reflect the local telephone company exchange boundary or
governmental jurisdiction where a customer is located, lives, or works. For example, a
CMRS provider in the Fairfield County area may serve a customer who uses his or her
phone in the customer’s home town, in Danbury, across the boarder in Westchester
County, New York or even while on vacation away from the area throughout New
England and all of these locations may be served by the same system as part of its
home calling area. Because mobile phone service is not associated with specific
geographic communities, the use of abbreviated dialing codes to permit wireless mobile
customers to access community services, such as those offered under or 311 codes,
must necessarily be designed and deployed differently than a comparable landline
offering.
The operational issues associated with the implementation of abbreviated N11
codes also constrain the potential benefits of N11 codes for wireless customers.
Wireless networks are unable to easily conform to defined political or geographic
boundaries. Wireless calls are established over a radio air link between the customer’s
mobile phone and a network cell site containing radio transmission equipment. Cell site
coverage areas never adhere to political boundaries and almost always span multiple
communities and frequently serve multiple counties or states. Cell site coverage areas
overlap each other as they serve portions of the communities within the network. In
many instances, wireless carriers’ FCC-licensed areas also differ from each other.
Therefore, the manner in which network call routing is designed and decided is not only
complex but is also unique to each wireless carrier’s network. In Connecticut, many VW
cell towers also serve the bordering states of New York and Massachusetts. Similarly,
20 Unlike wireline carriers, Commercial Mobile Radio Service (CMRS) carriers do not draw numbers from
every wireline rate center. Instead, they typically draw numbers from only a few rate centers and give
their customers “local” outbound calling over an extended area, regardless of the rate center
associated with the customer’s number. In Connecticut, for instance, VW draws numbers from a
minimal number of rate centers. By selecting from a limited number of rate centers in their calling
areas, and associating them with their large wireless network, CMRS carriers provide customers with
a very large local calling area. The end result is that the rate center of the mobile numbers has little to
do with the “local” calling area of the customers’ pricing plans or their community of interest.
Docket No. 02-06-12 Page 11
cell towers located in these bordering states also handle calls from wireless customers
physically located in Connecticut. These unique operational characteristics make the
imposition of N11 service rules on wireless providers unworkable. For instance, VW
questioned in its written comments which community’s services should the customer
access via the 311 code when the customer travels along and across various borders.21
VW asserts that wireless customers will likely use N11 services differently than
landline customers. Wireless networks operate differently from other wireless networks
and are operationally different than more predictable fixed landline networks. These
factors require full flexibility for CMRS carriers to work with N11 service providers to
deploy service in ways that best accommodate their wireless customers. 22
Based on its experience with the deployment of 211 dialing in Connecticut, the
Department concurs with the VW comments. Therefore, the Department recommends
that as the 311 deployment plan is developed, that special attention be afforded all
CMRS carriers taking into consideration the technical differences and difficulties that will
be placed on these service providers as they provide for 311 dialing.23
21 These same issues were experienced by the Department and Infoline when statewide 211 dialing was
implemented in Connecticut. Although the 211 dialing code to access Infoline was to begin no later
than January 1, 1999 for wireline service providers, it was not until 2002 before wireless carriers were
able to permit their end user subscribers to access Infoline by dialing 211.
22 VW Comments, p. 3.
23 Wireless providers typically deploy their abbreviated dialing codes on a market-wide or switch-wide
basis to accommodate the needs of their customers while working within the practical limitations of
their technology. This is usually accomplished through switch translation commands, entered into the
mobile switch, directing that switch to translate and route calls made via the abbreviated dialing code
to a single number. The translation command applies on a per-switch basis to every cell site served
by that switch, without exception. In larger markets that employ multiple switches, the same
translation command is loaded into each switch, effectively providing abbreviated dialing to the entire
market.
Based a Petition for Reconsideration filed by VW at the FCC in CC Docket No. 92-105, The Use of
N11 Codes and Other Abbreviated Dialing Arrangements (VW Petition), dated March 12, 2001, the
Department believes that wireless carriers may be required to engineer a more complex and extremely
labor-intensive technical fix in order to accommodate the individual requests of each community or
agency. By enabling each community to request calls to be routed to their unique information and
referral service number, wireless carriers would be required to engineer a per-cell routing requirement
instead of a system-wide or per-switch solution. Per-cell routing would be burdensome, time
consuming and complex to establish and maintain:
-- Working first from cell site coverage maps and maps of the communities served, engineers would need
to determine which cell sites or portions of cell sites served that particular community information and
referral service. VW suggests that care be taken to ensure that calls originated from the community
are routed to the community, but because radio propagation is imperfect there would be instances
where customer calls will not be routed to the community information service in which their call
originated.
-- Per-cell routing for those cells identified would require building translation tables for each cell or cell
face. This involves sitting down at a terminal and typing in tables of how dialing patterns should be
processed for that cell. A switch translator that some carriers use in their networks would change the
abbreviated digits dialed by the customer from that cell site/face to the number for the local community
information and referral service.
-- Once the highly detailed tables have been created for each cell they must be maintained for all system
changes that would affect these dialing plans. A number of everyday systems engineering changes
may trigger translation table changes such as adding cell sites, sectoring cell sites, or re-homing cell
sites. For instance, when new cells are added within the community, a new table would need to be
Docket No. 02-06-12 Page 12
G. ACCESS TO CONNECTICUT 311 SERVICE
Additional factors that must be addressed once the 311 non-emergency network
design has been agreed upon, include whether deployment of Connecticut 311 Service
would be phased-in or placed into service via a flash cut. A determination as to the
hours of operation and availability for call answering centers should also be made. Will
the state oversee Connecticut 311 Service or will oversight be delegated to the cities
and municipalities? Finally, a decision should be made as to how access to
Connecticut 311 Service would be made. That is, in addition to wireline and wireless
service access, will Connecticut 311 Service be accessed via an Internet web site, e-
mail communications or both?
H. EDUCATION PLAN
Prior to implementation of Connecticut 311 Service, a public education program
should be developed and executed. The State of Connecticut, local cities and
municipalities, DPS 911 and Infoline 211 (if appropriate) and telecommunications
service providers should develop a communications strategy, develop promotional
materials and produce various events designed to raise the public’s awareness of the
availability of Connecticut 311 Service, the appropriate uses of 311 service and when
911 should be dialed. A 311-web site could also be developed (similar to that used by
the Washington DC Metropolitan Police Department) that explains 311 service, when it
should be called, etc. Local municipal and law enforcement officials can also make
presentations at community and Neighborhood Watch Meetings to inform their
constituents of the service. Lastly, local telecommunications service providers should
be contacted concerning the possibility of including information in monthly customer
service bills and/or assisting in the production of public service announcements and
communications for newspapers, radio and television.
IV. CONCLUSION
Special Act 02-16 has required the Department to submit its Plan for 311 service
to the Legislature. In light of the above, the Department submits the proposed
Connecticut 311 Service Plan:
1. Determine the types of services (i.e., city services or non-emergency police calls)
that would be provided to callers dialing 311.
2. Conduct a comprehensive review of the DPS 911 and Infoline callings statistics.
created that accepts and translates the abbreviated dialing code. New cells are usually added along
with a decrease in the coverage of existing cells. The same process that took place initially to map out
cell coverage would need to be undertaken again for all modified cells to reverify that the cells
continue to serve the community and if not the tables would be amended. These reviews and
changes would also be required for other changes in radio propagation when converting cells from
omni to directional, down tilting or changing radios and changing radio power level settings. VW
Petition, pp. 13-15.
Docket No. 02-06-12 Page 13
3. Survey Connecticut cities and towns to measure local demand for the service(s)
as well as assess the type of municipal services that could be accessed through
dialing 311.
4. Conduct a demand/opinion survey of prospective users of Connecticut 311
Service.
5. Identify and develop the appropriate network design that Connecticut 311
Service will utilize.
6. Investigate and quantify the start-up and ongoing equipment and network costs
associated with the provision of Connecticut 311 Service.
7. Develop a Connecticut 311 Service funding program.
8. Meet with the 311 service software vendors, the wireline and CMRS industries to
identify technical issues and develop a network deployment schedule that
addresses those issues and permits end users to timely access Connecticut 311
in a timely manner. Particular attention should be paid to the technical issues
plaguing the wireless industry.
9. Develop a Connecticut 311 Service time line identifying all project milestones.
10. Determine how Connecticut 311 Service will be implemented (i.e., phased-in or
on a flash cut basis). Determine the oversight that would be afforded
Connecticut 311 Service and 311 call center hours of operation.
11. Develop and execute a public awareness program informing the public of the
availability of Connecticut 311 Service.
DOCKET NO. 02-06-12 DPUC IMPLEMENTATION OF A STATE-WIDE 311
NUMBER
This Decision is adopted by the following Commissioners:
Jack R. Goldberg
John W. Betkoski, III
Linda J. Kelly
CERTIFICATE OF SERVICE
The foregoing is a true and correct copy of the Decision issued by the
Department of Public Utility Control, State of Connecticut, and was forwarded by
Certified Mail to all parties of record in this proceeding on the date indicated.
Louise E. Rickard Date
Acting Executive Secretary
Department of Public Utility Control
ATTACHMENT 1
Substitute Senate Bill No. 308
Special Act No. 02-16
AN ACT CONCERNING A STATE-WIDE 311 NUMBER AND A REVERSE 911
NUMBER.
Be it enacted by the Senate and House of Representatives in General Assembly
convened:
Section 1. (Effective July 1, 2002) The Department of Public Utility Control shall, within
available appropriations, in conjunction with the Department of Public Safety and
Infoline of Connecticut, develop a plan for the implementation of a state-wide
nonemergency governmental telecommunications service to be known as 311 service.
Not later than January 1, 2003, the Department of Public Utility Control shall submit
such plan to the joint standing committee of the General Assembly having cognizance
of matters relating to energy and technology in accordance with the provisions of
section 11-4a of the general statutes.
Sec. 2. (Effective July 1, 2002) The Department of Public Safety shall, within available
appropriations, develop a plan for the implementation of a state-wide reverse 9-1-1
system. Not later than January 1, 2003, the department shall submit such plan to the
joint standing committee of the General Assembly having cognizance of matters
relating to public safety in accordance with the provisions of section 11-4a of the general
statutes.
Approved June 13, 2002
ATTACHMENT 2
Before the
Federal Communications Commission
Washington, D.C. 20554
)
) FCC 97-51
)
)
In the Matter of )
The Use of N11 Codes and Other ) CC Docket No. 92-105
Abbreviated Dialing Arrangements )
)
)
)
)
)
FIRST REPORT AND ORDER
AND FURTHER NOTICE OF PROPOSED RULEMAKING
Adopted: February 18, 1997 Released: February 19, 1997
By the Commission:
Comment Date: March 31, 1997
Reply Comment Date: April 30, 1997
TABLE OF CONTENTS
Paragraph No.
I. Introduction 1
II. Background 4
III. First Report and Order 13
A. Analysis 13
1. Jurisdiction/Numbering Authority 13
2. Mandatory Assignment of N11 Codes 14
for Provision of Information Services
3. National Assignment of Specific N11 Codes 22
a. Background 22
b. Emergency Services (911) 23
c. Access to Government Services 24
d. Access to Repair Services (611)
and Business Office Uses (811) 45
e. Directory Assistance (411) 47
f. Access to Telecommunications Relay
Services 49
4. Statutory Preemption
57
5. Other Issues 59
a. Alternate Abbreviated Dialing Arrangements 59
b. Recall Procedures 63
6. Regulatory Flexibility Act 65
IV. Further Notice of Proposed Rulemaking 66
A. Introduction 66
B. Access to Telecommunications Relay Services 67
C. Sale or Transfer of N11 Codes 69
D. Administration of N11 Codes 72
E. Procedural Matters 76
1. Ex Parte Presentations 76
2. Regulatory Flexibility Act 77
F. Comment Filing Procedures
78
V. ORDERING CLAUSES 81
Appendix A: Comments Filed on N11 NPRM
Appendix B: Comments Filed on TRS Petition
Appendix C: Comments Filed on GSA Petition
Appendix D: Comments Filed on Department of Justice Request
Appendix E: Final Regulatory Flexibility Analysis
Appendix F: Initial Regulatory Flexibility Analysis
2
I. INTRODUCTION
1. In 1992, the Commission adopted a Notice of Proposed Rulemaking
proposing that incumbent local exchange carriers (incumbent LECs) be required to
provide abbreviated dialing arrangements.24 "Abbreviated dialing arrangements" are
telephone numbers of less than the standard 7 or 10 digits. Among abbreviated dialing
arrangements, "N11 codes" are 3-digit telephone numbers of which the first digit may be
any digit other than 0 or 1, and the last two digits are both 1.25 Since the N11 NPRM
was released, various parties have asked that the Commission designate N11 codes for
a variety of applications,26 including, for example, to facilitate network access: (1) for
individuals with hearing or speech disabilities; (2) to information services; (3) to federal
and state government agencies; and (4) to non-emergency police services.
2. Under the amendments to the Communications Act of 1934 (the Act) in
the Telecommunications Act of 1996,27 the Commission has exclusive jurisdiction over
"those portions of the North American Numbering Plan that pertain to the United
States."28 The Commission also has authority to delegate to "State commissions or
other entities all or any portion of such jurisdiction."29 In this First Report and Order, we
allow the incumbent LECs, in addition to the states and Bell Communications Research
(Bellcore), to continue to perform the N11 code administration functions that they
performed at the time of enactment of the 1996 Act amendments to the 1934 Act, until
further Commission action. We also adopt several other important measures regarding
abbreviated dialing arrangements. Specifically, we respond to a request for an N11
code that could be dialed to reach non-emergency police services by assigning 311 on
24 See The Use of N11 Codes and Other Abbreviated Dialing Arrangements, CC Docket No. 92-105, 7
FCC Rcd 3004 (1992) (N11 NPRM). Appendix A lists those parties filing comments and reply comments
in response to the N11 NPRM.
25 Under the North American Numbering Plan (NANP), N11 codes are known as service codes. The
NANP is the basic numbering scheme for the telecommunications networks located in Anguilla, Antigua,
Bahamas, Barbados, Bermuda, British Virgin Islands, Canada, Cayman Islands, Dominica, Dominican
Republic, Grenada, Jamaica, Montserrat, St. Kitts & Nevis, St. Lucia, St. Vincent, Turks & Caicos
Islands, Trinidad & Tobago, and the United States (including Puerto Rico, the U.S. Virgin Islands, Guam
and the Commonwealth of the Northern Mariana Islands).
26 National Center for Law and Deafness and Telecommunications for the Deaf, Inc. (NCLD Petition),
filed October 1, 1993. Appendix B lists the parties filing comments and replies in response to the NCLD
Petition. GSA, Petition for Declaratory Ruling (GSA Petition), filed March 11, 1994. Appendix C lists the
parties filing comments and replies in response to the GSA Petition and the National Association of State
Telecommunications Directors, ex parte Presentation in CC Docket No. 92-105, September 22, 1993.
27 Telecommunications Act of 1996, Pub. L. No. 104-104, 110 Stat. 56 (1996).
28 47 U.S.C. § 251(e)(1).
29 Id.
3
a nationwide basis for this purpose.30 Wherever 311 is currently in use for other
purposes, however, we would allow that use to continue until the local government in
that area was prepared to activate a non-emergency 311 service. In this First Report
and Order we also conclude that, as the incumbent LECs can do currently, all providers
of telephone exchange service must be able to have their customers call 611 and 811 to
reach their repair and business service offices. We also conclude that a LEC may not
itself offer enhanced services31 using a 411 code, or any other N11 code, unless that
LEC offers access to the code on a reasonable, nondiscriminatory basis to competing
enhanced service providers in the local service area for which it is using the code to
facilitate distribution of their enhanced services. Finally we respond to a request for an
N11 code that could be used throughout the nation to reach telecommunications relay
services (TRS) by directing Bellcore to assign 711 on a nationwide basis for this use.
We decline, however, to: (1) mandate that N11 numbers be made available for access
to information services;
(2) mandate that an N11 code be designated for access to government agencies; or (3)
disturb the current allocation of various N11 codes for access to emergency services, 32
directory assistance, and LEC repair and business offices.
3. In the Further Notice of Proposed Rulemaking (FNPRM) we ask for
comment on the technical feasibility of implementing 711 for TRS access. We also ask
parties: (1) if it would be possible to develop within a reasonable time an N11
"gateway" offering access to multiple TRS providers; (2) whether, with such gateway
access, TRS calls would still be answered within our mandatory minimum standards for
TRS answer times; (3) whether such a gateway would be consistent with Section 255 of
the Act; and (4) whether any other important disability services could be accessed
through the same gateway. Regarding TRS, the FNPRM also requests comment from
interested parties, particularly TRS providers, about the possibility of providing both
voice and text TRS services through the same abbreviated N11 code. Finally, we ask
for comment on the proprietary nature of N11 codes and on our proposal to transfer the
administration of N11 codes at the local level from the incumbent LECs to the NANP
administrator.
30 Assignment means that a numbering plan administrator announces to the industry that a particular
number will be used for certain, defined services. This warns current users of that number that they will
need to relinquish their use of the number when the new assignment is implemented. Implementation
involves, among other things: relinquishing current local uses for the number; preparing switches for the
new, assigned use; modifying switches to route calls; and installing additional switching or other
equipment required to provided the services contemplated.
31 The term "enhanced services" refers to services, offered over common carrier transmission facilities
used in interstate communications, which employ computer processing applications that act on the
format, content, code, protocol or similar aspects of the subscriber's transmitted information; provide the
subscriber additional, different, or restructured information; or involve subscriber interaction with stored
information. See Section 64.702 (a) of the Commission's Rules, 47 C.F.R. §64.702(a). For purposes of
this proceeding, information and enhanced services are used interchangeably.
32 As discussed within, 911 has been designated as a national code for emergency services.
4
II. BACKGROUND
4. Prior to enactment of the 1996 Act amendments to the 1934 Act, Bellcore,
the states, the incumbent LECs, and the Commission each performed functions relating
to the administration of N11 codes. Since the AT&T divestiture, Bellcore has served as
the administrator of the NANP. Bellcore has assigned N11 codes for national use. In
addition, the Commission may direct Bellcore to assign an N11 code for national use if
the Commission determines that such a national assignment is appropriate. 33 Bellcore,
in its role as NANP administrator, has issued specific guidelines addressing the use of
N11 codes.34 Bellcore has stated that it has made no additional national assignments in
the last few years, pending resolution of the instant proceeding. Bellcore guidelines
recognize four N11 codes as assigned for national use: 411 (local directory
assistance); 611 (repair service); 811 (business office); and 911 (emergency
services).35 Bellcore also has stated that the remaining N11 codes, listed as
"unassigned," along with any assigned codes that are not used locally (611 and 811 in
some areas), would be kept available for future assignment by the NANP
administrator.36
5. Bellcore guidelines permit local use of N11 codes provided that such
assignments and use can be discontinued on short notice.37 In states where N11 codes
have been used locally, state public utilities commissions have directed the LECs to
assign and administer these codes. The specific procedures for assignment of N11
codes for local use vary from state to state. Three local N11 codes have been assigned
for particular uses in at least some LEC service areas (411 for local directory
assistance; 611 for LEC repair service; and 811 for LEC business office use).
33 711 is currently used in Canada for relay service for the hearing disabled. In a letter dated September
8, 1993, the Canadian Steering Committee on Numbering (CSCN) confirmed "the assignment of 711 as
the access code for relay service for the deaf . . . and [stated that it had] negotiated the assignment of 1-
800-855-0511 as the national 800# for access to MRS [message relay service]." See September 8,
1993 letter from B.M. Stevens, Secretary CSCN, Canadian Numbering Administrator, to its "distribution
list" advising the Canadian industry of changes. CSCN was established under the authority of Industry
Canada (the Canadian agency that regulates telecommunications services and their providers in
Canada) to advise it on an ad hoc basis. It has been confirmed with Industry Canada that in February
1994, both 711 and 1-800-855-0511 were implemented for relay service in Canada. The 711 number is
used by the hearing disabled to access the relay service, while the 1-800-855-0511 number is used by
the hearing to access the relay service.
34 See Bell Communications Research, BOC Notes on the LEC Networks -- 1994 (Issue 2), April 1994
(Network Notes), "Numbering Plan and Dialing Procedures."
35 See id. at 3.4. Thirty years ago, AT&T designated 911 for access to emergency services.
36 Id. at 3.4.1.
37 Id.
5
6. The Commission, in the NANP Order,38 adopted a new model for
administration of the NANP by announcing its intent to establish the North American
Numbering Council (NANC) under the Federal Advisory Committee Act.39 (The NANC
held its first meeting on October 1, 1996). The NANP Order did not specifically consider
the issue of service code allocation. In addition to holding that the NANP administrator's
existing functions will be transferred to an entity to be recommended by the NANC, the
Commission in the NANP Order also held that central office (CO) code administration
functions will be transferred from the LECs to the new NANP administrator to be
recommended by the NANC within 18 months after completion of the transfer of the
existing NANP administrative functions from the current NANP administrator.40 The
NANC will advise the Commission on numbering issues and also is charged with
recommending and guiding a neutral NANP administrator. Within the United States,
prior to enactment of the 1996 Act amendments to the 1934 Act, twelve regional CO
code administrators handled CO code assignments.41 Many LECs serving as CO code
administrators administered N11 codes for local use.42
7. On March 6, 1992, BellSouth petitioned the Commission to declare that
mandatory assignment of N11 codes for access to information services would be
consistent with the Communications Act and Commission policies.43 The petition was
prompted by a request from Cox Enterprises, Inc. (Cox), which had asked BellSouth to
assign it an N11 code in Atlanta for the purpose of offering information services. On
May 4, 1992, the Commission informed BellSouth that "there appears to be no
regulatory or legal impediment prohibiting BellSouth from currently assigning N11 codes
in a reasonable, non-discriminatory manner," which may include, for example, assigning
N11 codes on a first-come, first-service basis.44
8. On the same day that the Commission issued its letter to BellSouth, the
Commission adopted the N11 NPRM tentatively concluding that: (1) service codes 211,
38 Administration of the North American Numbering Plan, CC Docket No. 92-237, Report and Order, 11
FCC Rcd 2588 (1995).
39 5 U.S.C., App. 2 (1988).
40 NANP Order at para. 115.
41 The current telephone number format within the NANP is given by: NXX-NXX-XXXX, with the second
three digits representing CO code. The CO code administrators within the United States were:
Alascom; Ameritech; Bell Atlantic; BellSouth Corporation (BellSouth); Cincinnati Bell; GTE (for 813 area
code); GTE (for 808 area code); NYNEX; Pacific Bell; Southern New England Telephone; SBC; and U S
WEST.
42 See paras. 72-75, infra, for further discussion of administration of N11 codes.
43 BellSouth, Petition for Declaratory Ruling (BellSouth Petition), March 6, 1992.
44 Letter from Robert L. Pettit, FCC General Counsel, to David J. Markey, Vice President, BellSouth,
dated May 4, 1992 (May 4 1992 FCC General Counsel Letter to BellSouth).
6
311, 411, 511, 611, 711 and 811 should be available for abbreviated dialing 45 (2) N11
codes should be made available for abbreviated dialing until it is necessary to use the
codes as area codes;46 (3) LECs should not be subject to any additional restrictions on
how they allocate N11 codes;47 and (4) use of N11 service codes for information
services would not result in customer confusion.48
9. In light of these tentative conclusions, the Commission solicited comment
on the following broad issues: (1) whether LECs should be able to use 411 for delivery
of enhanced services; (2) whether continued LEC use of 611 and 811 represented an
efficient use of limited numbering resources that served the public interest; (3) whether
procedures for recalling N11 codes should be developed; (4) whether three digit dialing
should be available for purposes other than calling enhanced services; (5) whether sale
or transfer of N11 codes should be permitted; (6) whether restrictions should be placed
on the manner in which LECs allocate N11 codes if demand exceeds supply; (7)
whether LECs should be permitted to grant a preference to parties that "propose
innovative ways of using the company's network;"49
(8) what role state regulators should play in allocating N11 codes if demand exceeds
supply; (9) whether the use of N11 codes for information services results in customer
confusion; and (10) whether it is feasible to require other abbreviated dialing
arrangements to be made quickly available by LECs in lieu of or in addition to requiring
them to make N11 codes available.
10. In October 1993, the National Center for Law & Deafness and
Telecommunications for the Deaf, Inc. (NCLD) petitioned the Commission to direct the
assignment or reservation50 of two uniform N11 numbers. It requested 711 for access
to TRS by persons with speech and/or hearing disabilities and a second unspecified
service code for TRS access by voice and telephone users. On October 14, 1993, the
Commission released a public notice describing the petition and requested comments.51
45 See N11 NPRM at para. 12.
46 See id. at para. 13.
47 See id. at para. 16.
48 See id. at para. 18.
49 Id. at para. 16.
50 Parties refer both to assignment and to reservation. Throughout our discussion we will refer to
assignment. For a definition of "assignment," see footnote 7, supra.
51 Commission Requests Comment on Petition for Assignment of N11 Codes to Facilitate Access to
Telecommunications Relay Services, Public Notice, 8 FCC Rcd 7587 (1993) (TRS N11 Notice). See
also Commission Clarifies Pleading Cycle for Comments on Petition for Assignment of N11 Codes to
Facilitate Access to Telecommunications Relay Services, Public Notice, 8 FCC Rcd 8391 (1993).
7
11. In March 1994, the General Services Administration (GSA) filed a petition
requesting that an N11 code be reserved to facilitate nationwide public telephone
access to federal executive agencies.52 In a similar request, the National Association of
State Telecommunications Directors (NASTD), in an ex parte letter filed in this docket,
requested that a single N11 code be reserved to facilitate public access to state
agencies.53
12. In a letter dated August 26, 1996, the United States Department of
Justice's Office of Community Oriented Policing Services (Department of Justice) asked
that an N11 code, specifically 311, be reserved on a national basis for use by
communities for non-emergency police telephone calls. The Department of Justice also
suggested that the N11 code could be used to give access to other government
services, at the discretion of each jurisdiction. In a Public Notice dated September 10,
1996, the Commission sought comment on the Department of Justice's request.
III. FIRST REPORT AND ORDER54
A. Analysis
1. Jurisdiction/Numbering Authority
13. The Act states that, "[t]he Commission shall have exclusive jurisdiction
over those portions of the North American Numbering Plan that pertain to the United
States."55 Although the Act gives the Commission exclusive jurisdiction over those
portions of the NANP that pertain to the United States, the Act also allows the
Commission to delegate "to State commissions or other entities all or any portion of
such jurisdiction."56 As stated above, prior to enactment of the 1996 Act amendments
to the 1934 Act, Bellcore, the states, and the incumbent LECs each performed functions
relating to the administration of N11 codes. In Implementation of the Local Competition
Provisions of the Telecommunications Act of 1996, CC Docket No. 96-98, Second
Report and Order and Memorandum Opinion and Order, FCC 96-333 (rel. Aug 8, 1996).
(Local Competition Second Report and Order), the Commission stated:
52 GSA Petition at 3.
53 National Association of State Telecommunications Directors (NASTD), Ex Parte Presentation in CC
Docket No. 92-105, September 22, 1993.
54 Although this First Report and Order adopts several measures regarding abbreviated dialing
arrangements, it does not specifically adopt the rules proposed in the N11 NPRM. See N11 NPRM at
Appendix A.
55 See 47 U.S.C. § 251(e)(1). For this reason, the discussion of jurisdiction appearing in the N11 NPRM
and comments filed in response to that discussion are moot. The Act states that, "the term 'United
States' means the several states and Territories, the District of Columbia, and the possessions of the
United States, but does not include the Canal Zone." 47 U.S.C. § 153(50).
56 See id.
8
[w]e authorize Bellcore to continue to perform its functions as the North
American Numbering Plan Administrator in the same manner it did at the
time of enactment of the 1996 Act. We also allow the incumbent LECs to
continue to perform the CO code administration functions that they
performed at the time of enactment of the 1996 Act. Finally, we allow the
states, if they performed any number administration functions prior to
enactment of the 1996 Act, to continue to do so until such functions are
transferred to the new NANP administrator.57
As noted above, prior to enactment of the 1996 Act amendments to the 1934 Act, many
LECs serving as CO code administrators managed N11 codes for local use. In this First
Report and Order, we also allow the incumbent LECs, therefore, to continue to perform
the N11 code administration functions that they performed at the time of enactment of
the 1996 Act amendments to the 1934 Act. This is consistent with the Commission's
statement in the Local Competition Second Report and Order that the "transfer of
numbering administration functions will be a complex task, one that cannot be
accomplished immediately even on a transitional basis."58
2. Mandatory Assignment of N11 Codes for
the Provision of Information Services
14. Background. The N11 NPRM proposed to require LECs to
assign N11 codes to parties requesting them for information services unless and until it
is necessary to use the N11 numbers as area codes.59 The Commission tentatively
concluded that LECs should be permitted to select any reasonable method to allocate
N11 codes that would ensure fair and efficient number allocation.60
15. Comments. Commenters are divided on whether LECs should be
required to assign N11 codes for access to information services. Those supporting the
proposal contend that it would compel LECs to provide the public with convenient
access to such services.61 N11 access, they argue, would enable information service
providers to provide the public with information of significant local interest quickly and
57 Local Competition Second Report and Order at para. 329.
58 Id. at para. 330.
59 N11 NPRM at para. 13.
60 Id. at para. 16. The Commission did not set out specific allocation methods because reasonable
methods could vary with circumstances. For example, if supply exceeded demand, a first-come first-
served allocation method might be reasonable.
61 See, e.g., Alternative Weekly Newspapers, New Times, Inc., Sasquatch Publishing, City Pages, and
Tuscon Weekly (collectively, Alternative Newspapers) Comments at 4; Cox Comments at 2, Datatrex
Comments at 1; Infocom Comments at 1; Advance Reply Comments at 1.
9
conveniently.62 Such ease of access for consumers, they say, would, in turn, enhance
the viability of independent information service providers, putting them closer to an
equal footing with LECs and spurring competition. Cox asserts that enhancing
competition in information services markets is a long-standing Commission goal.63 In
an ex parte presentation, Cox emphasized that commercial uses of N11, such as
information services, which have received wide consumer acceptance, serve the public
interest and therefore necessitate the assignment of an N11 number. 64 The Alternative
Newspapers contend that N11 codes serve their needs far better than alternate dialing
arrangements, claiming that: (1) N11 provides customers an option that is "easier to
remember, easier to dial, and faster and quicker than seven or ten-digit alternatives;" (2)
900 services are too expensive for the local information services offered by the
alternative newspapers; and (3) the pricing and terms and conditions of the new 960
service are not know to the alternative newspapers.65 Local government agencies
involved in the provision of 911 emergency service contend that N11 codes should not
be available for assignment for commercial purposes, arguing that such use would
cause confusion regarding the use of 911 for emergency service 66 by increasing the
misdials to 911 in nonemergency situations67 and misdials to other N11 codes in
emergency situations.68
16. Among LECs filing comments, only BellSouth supports assignment of
N11 codes for information services.69 BellSouth argues that there is a need for
abbreviated dialing for information services that is not being met under the current
NANP. BellSouth suggests, however, that permissive allocation of N11 codes would be
preferable to mandatory allocation.70
62 See, e.g., NAA Comments at 2-3; Alternative Newspapers Comments at 2-3.
63 See Cox Reply Comments at 5 (citing Computer III Proceedings).
64 Cox December 12, 1995 ex parte presentation.
65 See Alternative Newspaper Comments at 3-5.
66 See, e.g., Shelby County, Tennessee Emergency Communications District (Shelby County)
Comments at 1-2; St. Charles Parish Communications District Comments at 1; St. Landry Parish
Communications District Comments at 1; Texas Advisory Commission on State Emergency
Communications (Texas Advisory Commission) Comments at 3-4.
67 See, e.g., Shelby County, Tennessee Emergency Communications District (Shelby County)
Comments at 1-2; St. Charles Parish Communications District Comments at 1; Claiborne Parish
Communications District Comments at 2.
68 See, e.g., Shelby County, Tennessee Emergency Communications District (Shelby County)
Comments at 2; West Carroll Parish Communications District Comments at 1.
69 See BellSouth Comments at i.
70 See Reply of BellSouth at 5. Accord Florida PSC Reply at 2.
10
17. Parties opposing mandatory assignment of N11 codes raise various
concerns. Some argue that mandatory assignment of N11 codes could disrupt current
use of an N11 code in some geographic areas,71 while others argue that some LECs
utilize older switching equipment that might not be able technologically either to handle
N11 codes or to bill accurately.72 Some parties believe that N11 codes should be
reserved for non-commercial public service uses.73 Other objections raised include: the
strong likelihood that demand will exceed supply; 74 the likelihood of consumer confusion
if services using N11 codes vary from area to area;75 the difficulty of reclaiming such
codes if the Commission later determines that the public interest requires reclamation;76
the possible challenges to the Commission's jurisdiction over codes used locally; 77 the
use of N11 codes as prefixes, platforms, or gateways to reach a menu of service
providers rather than just a single provider;78 the availability of alternative dialing
arrangements;79 the likelihood of extensive litigation;80 the perceived problems caused
by multiple LECs providing N11 codes in a local dialing area; 81 the potential for
problems if interexchange carriers obtain N11 codes;82 and the problems of
implementing call blocking on pay-per-call N11 numbers.83 Some parties also argue
71 See, e.g., APCC Comments at 3; ATU Comments at 1; Bellcore Comments at 5; OPASTCO Reply
Comments at 2.
72 See, e.g., GTE Comments at 4; USTA Comments at 17; U S WEST Comments at 16.
73 See, e.g., Ameritech Comments at 5; CSCN Comments; U S WEST Comments at 6; NYNEX Reply
Comments at 2; NCLD Reply Comments at 9.
74 See, e.g., Ad Hoc Telecommunications Users Committee (Ad Hoc) Comments at 6; Ameritech
Comments at 2; SNET Comments at 3; GTE Reply Comments at 5; Sprint Reply Comments at 3.
75 See, e.g., Ad Hoc Comments at 3; AT&T Comments at 4; Ameritech Comments at 8; ARRC Reply
Comments at 6; OPASTCO Reply Comments at 4.
76 See, e.g., Bellcore Comments at 5; BONA Comments at 4; SWBT Comments at 9.
77 See, e.g., ATU Comments at 2; NTCA Comments at 5; Pacific Comments at 17; NYPDS Reply
Comments at 1.
78 See, e.g., AT&T Comments at 3; Bell Atlantic Comments at 2; IIA Comments at 1; SNET Comments at
5; ARRC Reply Comments at 7; Pacific Reply Comments at 3.
79 See, e.g., Ameritech Comments at 6; NYNEX Comments at 4; USTA Comments at 9; U S WEST
Comments at 10; NYPDS Reply Comments at 4; SWBT Reply Comments at 2.
80 See, e.g., Ameritech Comments at 10; Rochester Comments at 3; GTE Reply Comments at 2.
81 See, e.g., GTE Comments at 5; MFS Comments at 5; and OPASTCO Reply Comments at 3.
82 See, e.g., Pacific Comments 10; SWBT Comments at 7.
83 See PRTC Comments at 4.
11
that an abbreviated dialing arrangement (such as an N11 code) is merely a
convenience, and is not essential to making information services available to
consumers.84
18. Many commenters claim that the scarcity of such codes and the many
competing uses for them require that all the remaining N11 codes be devoted to public
service uses.85 Possible public service uses include multiple codes for emergency
services,86 special number services for persons with physical disabilities,87 and
telephone access to federal and state agencies.88 Information service providers urge
the Commission not to narrowly define public use as encompassing only nonprofit
entities. They assert that commercial uses of N11 codes serve the public interest by
providing the public access to information which is difficult for the general public to
obtain.89
19. Discussion. We decline to require LECs to make N11 codes available for
information services at this time. We anticipate that because only three to five N11
codes will be available in any given geographic area, demand for each N11 code is
likely to exceed supply.90 We agree with Rochester's argument that open assignment of
84 See, e.g., USTA Comments at 12; Sprint Reply Comments at 5.
85 See, e.g., Ameritech Comments at 5; CSCN Comments at 4; NCLD Reply Comments at 4; NYNEX
Reply Comments at 2; SWBT Reply Comments at 5.
86 See, e.g., Ameritech Comments at 6; NYNEX Comments at 4; Pacific Comments at 3.
87 See, e.g., BellSouth Reply Comments at 10, NYNEX Reply Comments at 2.
88 See GSA Petition.
89 See Media Parties (collectively, Cox Enterprises, Inc., Advance Publications, Inc., Gannett Co., Inc.,
The Hearst Corporation, The Washington Post Company) Reply Comments at 3-6.
90 Generally for most of the 50 states, 911, 411, and 611 are deemed to be "special services," and are
defined as services for which the caller either pays no charge or the charge is tariffed. This category
also includes services that require presubscription and provide access to customer services provided by
the LEC, including access to LEC repair services. See generally, "Central Office Code Usage Report",
Industrial Analysis Division, Common Carrier Bureau, Federal Communications Commission, July,1993
(FCC Report); "The Use of N11 Codes and Other Abbreviated Dialing Arrangements- State Survey",
Sandy Ibaugh, Indiana Utility Regulatory Commission, November, 1993 (NARUC Report). For a vast
majority of the states, the codes 211, 311, 511, and 711 are reserved for various purposes but are not
currently in use. See FCC Report at 3.
Some state regulatory commissions have granted assignments of N11 codes for commercial uses. By
the terms of the Commission's Local Competition Second Report and Order and this First Report and
Order, these grants, some of which are described below, are left in place. The Florida Public Service
Commission, for example, approved "511" for an information service run by Cox Communications' Palm
Beach Post as a two year experiment in 1993. State Telephone Regulation Report, Vol. 11, No. 16
(August 12, 1993). The State of Georgia has approved the use of "211" code for Cox Communications'
information service in Atlanta. NARUC Report at 9. The State of Hawaii has reserved 711 for TRS
access use. Some sections of Maryland use 711 for internal LEC use by telephone company
12
N11 codes is likely to invite "endless litigation over the reasonableness of an exchange
carrier's allocation plan."91 According to Rochester and others, this potentially could
draw the Commission into numerous decisions as to who should receive unassigned
N11 codes and for what purpose.92 As a result, we believe that the burden should be
on those who urge the Commission to require that LECs assign available N11 codes to
show that the benefits of such a requirement outweigh the costs. On the record before
us, we are not satisfied that supporters of such a requirement have met this burden.
20. The parties offer only conjecture that, from a user's perspective, using N11
codes significantly enhances the quality of access to information services. First,
although an N11 number for information services may be considered "novel," and might
be convenient for some users, it is by no means essential to making the service
available. Second, even assuming that consumers do perceive a benefit from such
abbreviated dialing arrangements, we find there are other ways currently available to
achieve convenient dialing that do not drain scarce N11 resources. In New York, for
example, information services are assigned a common central office prefix such as 540
or 970.93 As consumers associate these prefixes with information services, they need
remember only the last four digits of an information service provider's telephone
number. Such dialing arrangements appear to offer the same results as N11 without
the competitive concern of having to decide to whom the codes should be assigned.
21. We recognize the concerns expressed by some information service
providers that, absent Commission order, some LECs may unjustly or unreasonably
withhold N11 codes for local information services. As discussed in the FNPRM below,
we propose that the LECs' functions related to N11 administration94 be transferred to
the neutral NANP administrator to be recommended by the NANC. 95 With a neutral
employees. See FCC Report at 25 and 49. According to a staff member of the New York State
Department of Public Services, Teleport currently allows end users to dial 211 at its own payphones to
permit callers to access Port Authority Police for access to its emergency services. This use of 211 is in
addition to the use of 911 for access to emergency services at New York City PSAPS. While Teleport
does not use 211 in this manner as a result of an NYSDPS requirement, according to the NYSDPS staff
member, the NYSDPS does not prohibit such use. See E-mail reply from Yog Varma, NYSDPS, to
Elizabeth Nightingale, FCC, CCB, dated November 7, 1996.
91 Rochester Comments at 3.
92 See, e.g., Rochester Comments at 3; Ameritech Comments at 10; GTE Reply Comments at 2.
93 New York Telephone states that the 540, 550 and 976 prefixes currently available to enhanced service
providers allow for 30,000 seven-digit numbers within a LATA. By contrast, up to only eight N11 codes
would be available for local information services in the New York Telephone service area. See New
York Telephone Comments at 4.
94 By the terms of the Commission's Local Competition Second Report and Order and this First Report
and Order the incumbent LECs are permitted to continue performing functions related to N11
administration they performed prior to enactment of the 1996 Act amendments to the 1934 Act.
95 See NANP Order at para. 65-67.
13
administrator, the concerns of the information service providers should be mitigated.
We also note that when a LEC assigns N11 codes, it must do so in a reasonable, non-
discriminatory manner, such as on a first-come, first-served basis.96 Should, however,
there be particular problems related to the availability of one or more N11 codes from a
particular LEC serving as the administrator prior to the transfer of functions to a new
NANP administrator, parties can bring these unresolved disputes to our attention by
filing a complaint pursuant to Section 208. We also are prepared to address specific
problems even after a transfer of N11 code administration to a new entity.
3. National Assignment of Specific N11 Codes
a. Background
22. The N11 NPRM did not propose to disturb 911's existing designation as a
national code for emergency services97 nor did it propose to disturb the use of 411 for
local directory assistance. Currently, 411 directory assistance services are classified as
basic or adjunct to basic services for purposes of the Commission's rules even if those
numbers are not presently used in some geographic areas for those purposes. 98 In
addition, the Commission tentatively concluded: (1) that 211, 311, 511, and 711, which,
at the time of the N11 NPRM were "apparently not used at all,"99 should be available for
abbreviated dialing; and (2) that the 611 code now used by some LECs for repair
services and the 811 code now used for quick connection to LEC business offices
should also be available for abbreviated dialing.100
b. Emergency Services (911)
23. As stated above, AT&T designated 911 as a national code for reaching
emergency services. Commenters generally agree that the current use of 911 for
emergency services should remain unchanged.101 We find that use of a national
uniform N11 code for this purpose clearly serves the public interest because end users
96 See May 4 1992 FCC General Counsel Letter to BellSouth.
97 See footnote 12, supra, regarding AT&T's designation of 911 as a national code.
98 N11 NPRM at para. 11. A basic service is an offering of transmission capacity between two or more
points suitable for a user's transmission needs, and subject only to the technical parameters of fidelity
and distortion. See North American Telecommunications Association, Petition for Declaratory Ruling
Under Section 64.702 of the Commission's Rules Regarding the Integration of Centrex, Enhanced
Services, and Customer Premises Equipment, 101 FCC 2d 349, 358 at para. 23 (1985) NATA Centrex
Order), recon., 3 FCC Rcd 4385 (1988). An adjunct to basic service is a service that might fall within a
literal reading of our definition of enhanced service (see footnote 8, supra) but which is clearly basic in
purpose and use and which brings maximum benefits to the public through its provision in the network.
99 N11 NPRM at para. 8.
100 Id. at para. 12.
101 See, e.g., Ameritech Comments at 7; Sprint Reply Comments at 4.
14
know that they can dial this code from virtually any exchange in the country in order to
obtain emergency assistance. Moreover, 911's virtual ubiquity and long-standing
nationwide status as the phone number for quick and easy access to emergency
services along with the absence of equally useful numbers for this important public
purpose, supports its continuing use.102 We, therefore, do not intend to alter 911's
designation as a national code.103
c. Access to Government
Services
24. Background. GSA, in its petition, requests that the Commission assign an
N11 number for access to federal government agencies. GSA proposes that callers
dialing the GSA N11 code be connected to a menu of services, and select the federal
agency or service desired by responding to recorded prompts.104 GSA also contends
that such an N11 assignment would serve the public interest by providing easy access
to the federal government through a uniform nationwide three-digit code. NASTD seeks
uniform nationwide assignment of an N11 code, specifically 211, to facilitate public
access to state agencies.105 NASTD, in comments supporting its request, argues that
such a number would serve the public interest because: (a) virtually everyone needs
the services of state agencies at one time or another; (b) state government institutions
and programs would be made more readily available to state citizens; and (c) national
uniformity would enhance accessibility regardless of the state in which a person
happens to be located.106 The Department of Justice, in its request, asks that the
102 The Minnesota Department of Administration 911 Program, based on a compilation of state-by state
estimates of population coverage as of late 1996, estimates that approximately 87 percent of the
population in the United States is served by 911. See, facsimile transmission from Jim Beutelspacher,
Minnesota 9-1-1 Program to Elizabeth Nightingale of the FCC Common Carrier Bureau dated November
22, 1996.
103 In an Order released July 26, 1996, the Commission adopted rules regarding enhanced 911 (E911)
emergency service for wireless providers. See In The Matter of Revision of the Commission's Rules to
Ensure Compatibility with Enhanced 911 Emergency Calling Systems, CC Docket No. 94-102, RM-8143
Report and Order and Further Notice of Proposed Rulemaking, FCC 96-264 (released July 26, 1996)
(Wireless E911 Report and Order and FNPRM). The Commission, also in CC Docket No. 94-102,
currently is considering establishing E911 rules in the wireline context. See Revision of the
Commission's Rules to Ensure Compatibility with Enhanced 911 Emergency Calling Systems, Notice of
Proposed Rulemaking, 9 FCC Rcd 6170 (1994). We also note that, under the Act, BOCs, before they
are permitted to offer in-region, interLATA services, must show that the access or interconnection they
offer to other telecommunications carriers includes, among other things, "non discriminatory access to . .
. 911 and E911 services." 47 U.S.C. §271(c)(2)(B)(vii)(I). We highlight this obligation here to emphasize
the duty imposed by Congress on each BOC to provide competitors with nondiscriminatory access to
911 and E911 services.
104 GSA Petition at 2-3.
105 See NASTD September 22, 1993 Letter to FCC Commissioner Quello. Comments filed in response
to the GSA and NASTD requests will be referred to as Government Comments.
106 NASTD Government Comments at 2.
15
Commission reserve an N11 number, specifically 311, for use for non-emergency police
telephone calls and suggests that the number could be used to give access to other
government services, at the discretion of each jurisdiction.
25. Comments. While many commenters agree that N11 codes should be
assigned for national public use, and acknowledge the benefit of quick and convenient
public access to government services, commenters are divided on the issue of whether
these services warrant a national N11 assignment. Several commenters support
assignment of a national N11 code for access to government services.107 For example,
the City of Dallas (Dallas) "urge[s] the Commission not only to assign a 3 digit number
for national usage of Federal Government offices, but also one for local government and
one for state government use."108 In noting that it is seeking use of an N11 code
(preferably 511) for access to its city's services, Dallas asserts that "use of a simple to
dial, easy to remember number will aid in our desire to be more responsive and
accountable to our citizens."109 Dallas notes the N11 usage it seeks is similar to that
proposed by GSA. The Tennessee Valley Authority (TVA) supports the Commission's
proposal to establish a national N11 code, arguing that such a code would provide
greater awareness and access to its services.110 The United States Department of
Agriculture (USDA) claims that use of a national N11 code will enable it to more
effectively control their emergency preparedness programs in times of natural
disaster.111 Further, USDA suggests that the use of an N11 code will encourage public
calls on a more timely basis, thereby increasing efficiency and its ability to serve the
public.112
26. Nevertheless, many argue that it would be premature to grant GSA's or
NASTD's request at this time. MCI and Sprint, for example, argue that the Commission
should first establish a comprehensive policy governing assignment of available N11
107 See, e.g., Overseas Private Investment Corporation Government Comments at 2; City of Dallas
Government Comments at 2; Tennessee Valley Authority Government Comments at 2.
108 Dallas Government Comments at 2.
109 Id. at 1.
110 TVA Government Comments at 2.
111 USDA Government Comments at 1.
112 Several federal executive agencies take the same position with respect to increased efficiency and
public responsiveness. See, e.g., Department of Health and Human Services (DHHS) Government
Comments at 2; The Department of Justice Government Comments at 2; U.S. Department of
Transportation (DOT) Government Comments at 2; Department of Veteran Affairs (VA) Government
Comments at 3; Environmental Protection Agency (EPA) Government Comments at 2; Overseas Private
Investment Corporation (OPIC) Government Comments at 2; Consumer Products Safety Commission
(CPSC) Government Comments at 1; National Aeronautics and Space Administration (NASA)
Government Comments at 1.
16
codes, including codes assigned to the government.113 NENA expresses concerns
about possible public confusion between N11 codes for emergency and non-emergency
government information programs.114 As noted above, in opposing assignment of N11
codes for commercial purposes, several agencies also express concern about
confusion with 911. Several of these parties ask that the Commission not allow any
new N11 code assignments, or in the alternative, if the Commission decides to allow
new assignments, limit the new assignments to access to public service and
governmental entities.115 The Caddo Parish Communications District Number One
(Caddo Parish) cautions that if the Commission grants the GSA and NASTD requests,
close cooperation will be needed between local governments operating 911 emergency
systems and all Federal and State agencies participating in the use of the N11
number.116 There is also concern expressed that there are numerous technical and
cost issues that must be resolved before abbreviated codes can be implemented. For
example, BellSouth notes that the N11 use contemplated by GSA has not yet been
tested.117 GSA responds that alleged technical and other barriers are not
insurmountable and that, in any event, it does not envision a "flash cut" to ubiquitous
nationwide access to its proposed information services.118 Finally, the Ad Hoc
Telecommunications Users Committee (Ad Hoc) argues that the GSA request, as well
as the state requests, should be denied. Ad Hoc suggests that the Commission act
expeditiously to ensure that N11 codes are allocated on a uniform national basis 119 and
acknowledges that an N11 code may provide users with the benefits of ease and
recognition.120 Ad Hoc argues, nonetheless, that GSA fails to demonstrate a compelling
need for the assignment.121
27. Acadian Ambulance Service, Inc. (Acadian), a privately-owned ambulance
service in Louisiana using 311 since August 1, 1994,122 supports the Commission's
113 See MCI Government Comments at 3-4; Sprint Government Comments at 3.
114 NENA Government Reply Comments at 3.
115 See, e.g., Texas Advisory Commission Government Comments at 4-5; Jackson Parish 9-1-1
Communication District Government Comments at 1.
116 See Caddo Parish Government Reply Comments at 7.
117 BellSouth Government Comments at 6-7.
118 GSA Government Reply Comments 13-14.
119 Ad Hoc Government Comments at 4.
120 Id. at 7.
121 Id. at 7-8.
122 Acadian states that is serves 23 Louisiana parishes.
17
proposal in the N11 NPRM that LECs be required to provide abbreviated dialing
arrangements. Acadian states that customer confusion will not result from the use of
abbreviated dialing arrangements,123 but requests that the Commission provide
grandfathering preferences for medical communications systems "that are already
saving lives on existing N11 service code authorizations."124 Acadian requests that the
grandfathering include retaining existing medical and emergency services' use of N11
codes as authorized by other governmental bodies, such as state public service
commissions, and requiring recall of N11 codes used for emergency services (after a
minimum one-year notice period) only after the recall of those used for other services.125
According to Acadian, these grandfathering preferences are warranted because of the
life-saving services provided by emergency communications systems such as
Acadian's.126 Several local government agencies involved in the provision of 911
emergency service, while requesting that the Commission not allow any new N11 code
assignments, assert that if the Commission decides to allow new assignments, the new
assignments should be limited to access to public service and governmental entities.127
28. Many parties filing comments128 in response to the Department of Justice's
request for assignment of 311 for non-emergency police calls support that request.129
For example, asserting that their 911 systems have been overloaded by calls that may
not be of an emergency nature, various fire departments across the country filed
comments supporting national assignment of 311 as beneficial to their ability to deliver
emergency services.130 Asserting the need to reduce the number of calls placed to 911,
123 Acadian Comments at 4.
124 Id.
125 Id. at 4-5.
126 Id. at 5.
127 See, e.g., Texas Advisory Commission Government Comments at 4-5; Jackson Parish 9-1-1
Communication District Government Comments at 1.
128 The comments filed in response to the Department of Justice request are referred to as "311
Comments."
129 See, e.g., Ameritech 311 Comments at 2-3; AT&T 311 Comments at 2-3; National Association of
Police Organizations, Inc. (ANPO) 311 Comments; City of Austin Comments; Fire Commissioner/Chief
of the Boston Fire Department 311 Comments.
130 See, e.g., Dallas Fire Chief 311 Comments; Fort Worth Fire Chief 311 Comments; Fire Chief of the
City of Pittsburgh, Department of Public Safety 311 Comments; Fire Chief of the Seattle Fire Department
311 Comments; Commissioner of the Philadelphia Fire Department 311 Comments; Fire
Commissioner/Chief of the Boston Fire Department 311 Comments. Cf. International Association of Fire
Chiefs, Inc., and International Municipal Signal Association (collectively, International Fire
Chiefs/Municipal Signal); Fairfax County Fire and Rescue Department 311 Comments.
18
various police departments131 and associations,132 as well as the National Sheriff's
Association133 and the National Troopers Coalition,134 support the Department of
Justice's request.
29. The Maryland Public Service Commission (MDPSC) filed comments
supporting the request in which it asserts that 911 is overburdened in many
jurisdictions135and provides information about the two-year trial in Baltimore (Baltimore
311 Trial), which commenced on October 2, 1996, and in which individuals in the City of
Baltimore may dial 311 for access to non-emergency police services.136 The MDPSC
asks that if the Commission does not grant the request that we refrain from taking action
that would compromise the Baltimore 311 Trial.
30. Several commenters, while supporting assignment of a non-emergency
number, express concern about issues related to implementation. These concerns
include issues such as routing, translation programming, funding and technical
compatibility with existing 911 systems.137 For example, APCO argues that addition of
this number may cause problems for development of wireless location technology for
911 services.138 CBT cautions that nationwide implementation of 311 will necessitate
translation programming in central offices so that 311 calls that are translated into a
standard seven-digit number in the central office switches will ring to the corresponding
131 See, e.g., The Dallas Police Department 311 Comments; the San Jose, California 311 Comments;
the San Bernadino, California Police Department 311 Comments; the Los Angeles Police Department
311 Comments; City and County of Denver Department of Safety, Chief of Police 311 Comments.
132 See, e.g., Maryland Chiefs of Police Association 311 Comments; National Association of Police
Organizations 311 Comments; National Fraternal Order of Police 311 Comments.
133 See National Sheriff' Association 311 Comments.
134 See National Troopers Coalition Comments.
135 See MDPSC 311 Comments at 3.
136 On October 31, 1996, the MDPSC filed two responses to requests for supplemental information by
Commission staff. See Response of the Maryland Public Service Commission to Request for
Supplemental Information From the Federal Communications Commission, CC Docket No. 92-105,
October 31, 1996; Response of the Maryland Public Service Commission to Request for Supplemental
Information From the Federal Communications Commission November 6, 1996 (November 6, 1996
Supplemental Filing).
137 See, e.g., Cellular Telecommunications Industry Association (CTIA) comments; Ameritech 311
Comments at 2-3; The Association of Public-Safety Communications Officials-International, Inc. (APCO)
311 Comments at 2-3; Cincinnati Bell Telephone Company (CBT) 311 Comments at 4-5; County of Los
Angeles 311 Comments at 2; Los Angeles Police Department 311 Comments; Texas Department of
Information Resources (Texas DIR) 311 Comments at 2-3.
138 APCO 311 Comments at 2.
19
local law enforcement agency.139 The County of Los Angeles expresses concerns
about expenditures, staffing and technical compatibility with 911 systems, such as
Automatic Location Identification (ALI) and Automatic Number Identification (ANI). 140
The Los Angeles Police Department contends, for example, that: a national non-
emergency N11 number should be supported by the same network selective routing
system as E911/911 to ensure appropriate routing of non-emergency and emergency
calls; the non-emergency calls should be supported with full ANI and ALI, provided
through the same database platform; and in the future network, as with 911 calls, 311
calls should be routed using signalling system 7 over the public switched telephone
network instead of on dedicated trunking.141 The Texas DIR supports the request, with
the stipulation that a local jurisdiction could provide access to other government
information and services,142 but asserts that the FCC must first consider such things as
the possibility of adverse impacts to 911 and that access to government information
should include all levels of government and both voice and data information.143 The
Texas DIR expresses concern that the Justice Department proposal does not address
funding, noting that for the Baltimore 311 project, the Justice Department has provided
$350,000 dollars to the City of Baltimore for the two-year project and that AT&T has
donated phone lines and invested over $1 million in the program.144
31. Parties also raise concerns about the ability to analyze the results of the
Baltimore 311 Trial prior to the Commission's making a determination in this
proceeding.145 Several other parties suggest that it is premature to make a
determination that 311 should be assigned for non-emergency police calls,146 claiming,
for example, that the issue should be referred to industry fora,147 that the Commission
139 See CBT 311 Comments at 4.
140 See County of Los Angeles 311 Comments at 2. Other commenters raise the issue of the use of ALI
for 311 non-emergency services. See, e.g., Cellular Telecommunications Industry Association (CTIA)
311 Comments (expressing concern about whether ALI would be required for 311); City of Houston 311
Comments (asserting that the 311 code will not require a dedicated telephone network because, unlike
911 ALI will not be needed).
141 See Los Angeles Police Department 311 Comments at 2.
142 See Texas DIR 311 Comments at 2.
143 See Id. at 2-3.
144 Id. at 2.
145 See, e.g., California Highway Patrol 311 Comments; Cox 311 Comments at 1-2.
146 See, e.g., GTE 311 Comments at 2-4; BellSouth 311 Comments at 3; The Office of Information
Resources of the Budget and Control Board of the State of South Carolina (South Carolina OIR) 311
Comments.
147 See, e.g., GTE 311 Comments at 2-4; BellSouth 311 Comments at 4-5.
20
should subject the issue to further scrutiny in the context of a broader review of
abbreviated dialing arrangements,148 and that alternative dialing arrangements such as
800 and seven-digit or ten-digit numbers should be considered.149 Several parties
opposing the Department of Justice's request also cite available 800, seven-digit and
ten-digit alternatives.150
32. Parties opposing the Department of Justice's request include entities
currently assigned 311 for local use, several state 911 communications centers,151 the
National Emergency Number Association (NENA)/National Association of State Nine
One One Administrators (NASNA) (collectively, National 911 Commenters), and the
International Association of Fire Chiefs, Inc., and International Municipal Signal
Association (collectively, International Fire Chiefs/Municipal Signal). Many parties
opposing the Department of Justice's request cite implementation concerns, 152 suggest
education efforts as an alternative,153 and caution that implementation of a non-
emergency number prior to ubiquitous 911 service would be detrimental to efforts to
make it so.154
33. The National 911 Commenters oppose the Department of Justice request,
arguing, for example, that 911 networks in most of the country are not overloaded;155
time and speed dialing are not important in non-emergency situations; N11 numbers,
unlike seven-digit and ten-digit numbers (such as 800 numbers) are scarce;
implementation is costly; and there are wide local variations of use of N11 numbers,
148 See South Carolina OIR 311 Comments.
149 See GTE 311 Comments at 2-4.
150 See, e.g., Texas Advisory Commission on State Emergency Communications (TX-ACSEC) 311
Comments at 2; Arizona APCO Chapter 311 Comments; Mesa 311 Comments at 1-2; King County E911
Program Manager Comments at 1-2; International Association of Fire Chiefs, Inc., and International
Municipal Signal Association 311 Comments at 9-11 (suggesting a 555 number alternative).
151See, e.g., City of Mesa, Arizona, Police Department Communications (City of Mesa) 311 Comments;
Southern Idaho Regional Communications Center 311 Comments; Greater Harris County 9-1-1
Emergency Network 311 Comments.
152 See, e.g., National 911 Commenters 311 Comments at 6-7; Arizona APCO Chapter 311 Comments;
City of Mesa 311 Comments at 1-2; International Fire Chiefs/Municipal Signal 311 Comments at 7-9.
153 See, e.g., Bismark Emergency Management & Combined Communications (Bismark) 311
Comments; Cox 311 Comments at 4; Greater Harris County 9-1-1 Emergency Network 311 Comments
at 1; Mesa Comments at 1; Southern Idaho Regional Communications Center 311 Comments; Fairfax
County Fire and Rescue Department 311 Comments; King County E911 Program Manager 311
Comments at 1; International Fire Chiefs/Municipal Signal 311 Comments at 7.
154 See, e.g., Mesa 311 Comments at 1; Arizona APCO 311 Comments at 1.
155 National 911 Commenters 311 Comments at 4.
21
which, in some cases are causing confusion for 911 callers.156 The National 911
commenters ask whether national uniformity is superior to local choice and also contend
that the Commission must consider that there are other pending requests for N11
numbers.157 The State of New York Department of Public Service (NYSDPS), while
supporting the concept of a national non-emergency police N11 number, opposes the
use of 311 for this purpose because this code is used in New York state by individuals
with hearing or speech disabilities to access New York State Police emergency
services.158 NYNEX also opposes the particular use of 311 for the same reason, but,
unlike NYSDPS, opposes the use of an N11 code for this purpose generally, on the
grounds that it may be too easily confused with 911. 159 NYNEX suggests, as an
alternative, an interchangeable numbering plan area (INPA) three digit code such as
222, 333, 444, 777 or 933, and any conflicts between the INPA and an NXX could be
resolved through "interdigital dialing" by having switches programmed to determine
whether an NXX is dialed after the INPA.160 Other opponents, like NYNEX, cite
possible confusion with 911 as a reason not to choose 311 as a non-emergency police
number.161 The City of Fresno, California Chief of Police (Fresno Police Chief), while
not objecting to a national three digit number for non-emergency police calls, contends
that the national number should not have any of the numbers contained in 911, and
suggests, for example, a number such as 333. The Fresno Police Chief also suggests
that the national number should not be mandatory and that if it is, "legislation be passed
to fund the cost of establishing and maintain[ing] the non-emergency telephone
system."162 Costs of upgrading the network and funding issues are raised not only by
opponents of the Department of Justice's request163 but also by its supporters who
express concern about implementation of 311.164
156 Id. at 6-7.
157 Id. at 8.
158 NYSDPS 311 Comments at 1.
159 See NYNEX 311 Comments at 2.
160 See id. at 3. See also Florence Cainoce, Staff Manager for NYNEX Consumer Affairs 311 Comments
at 2, stating that she is a member of the Deaf community and she hopes 311 will continue to be used in
New York for its current purpose until the year 2000.
161 See, e.g. National 911 Commenters 311 Comments at 8; Cox 311 Comments at 5-6; International
Fire Chiefs/Municipal Signal 311 Comments at 6.
162 Fresno Police Chief 311 Comments.
163See, e.g., City of Mesa 311 Comments at 2; Arizona APCO 311 Comments at 2; National 911
Commenters 311 Comments at 6-7; International Fire Chiefs/Municipal Signal 311 Comments at 8.
164 See, e.g., AT&T 311 Comments at 3; Los Angeles Police Department 311 Comments at 2;
22
34. Several other parties note current uses of 311. Acadian Ambulance and
AIR MED Services of Louisiana (Acadian et. al.),165 while generally supporting the non-
emergency number effort, opposes the selection of 311, which it has been using since
March 1994 to provide rural ambulance service in Louisiana. Acadian et al. requests
that the Commission, if it chooses 311 as a national non-emergency number, direct the
Louisiana PSC to award Acadian a replacement number. 166 The Kentucky Department
of Transportation (Kentucky DOT) and the Ohio Department of Transportation (Ohio
DOT), while both supporting the assignment of a national non-emergency N11 number,
object to the choice of 311 because each uses that number in its state for traffic
information. The Ohio DOT cites its current cellular use of the number and pending
request for landline use for the Advanced Regional Traffic Interactive Management and
Information System (ARTIMIS), a traffic management system that according to the Ohio
DOT has been very successful.167 The Kentucky DOT states that it views N11 as a
scarce numbering resource that should be assigned for public, rather than private
projects, but contends that it has spent much money, including a "business opportunity"
fee of $45,000.00 per year to Cincinnati Bell Telephone Company (CBT), for its use of
311.168 The Kentucky DOT suggests 611 as an appropriate number, contending that
very few telephone customers actually know that this number can be used for telephone
company repair calls.169 CBT, although expressing implementation concerns and noting
the Kentucky DOT's current use of 311, supports the Department of Justice's request.170
Morris Communications Corporation (Morris) of Augusta, Georgia, opposes the request
because the company uses 311 in three cities in Georgia and one in Florida as a pay-
per-call number providing updates on, for example, news, sports and entertainment.
Morris requests that a different three digit code be used, suggesting that 811 might be
better because it immediately precedes 911.171 Finally, Morris states that it would
investigate whether its legal rights would be infringed by a "taking" of the 311
number.172
165 Acadian Ambulance Service, Inc. (Acadian) filed comments in response to the N11 NPRM. See para.
28, supra. Acadian filed together with AIR MED Services of Louisiana (Acadian et. al.) in response to
the Department of Justice request. Acadian et. al. states that it serves 26 Louisiana parishes, three
more than Acadian said it served in 1994.
166 See Acadian et. al 311 Comments at 2-4.
167 See Ohio DOT 311 Comments at 1-2.
168 See Kentucky DOT 311 Comments at 2.
169 Id.
170 See CBT 311 Comments at 2.
171 See Morris 311 Comments at 1.
172 Id. The Commission has stated that carriers do not own numbers and that numbers are a national
public resource. See para. 71, infra.
23
35. Discussion. We find assignment of a national number through which the
public could gain access quickly to non-emergency police and other government
services173 to be in the public interest. After reviewing the record, we conclude that this
number should be an N11 code, specifically 311. We direct Bellcore, as of the effective
date of this First Report and Order, in its capacity as NANP administrator, to assign 311
for this purpose. When a provider of telecommunications services receives a request
from an entity (for example a local police chief or local fire chief) to use 311 for access
to non-emergency police and other government services in a particular jurisdiction, it
must ensure that, within six months of the request: (1) entities that were assigned 311
at the local level prior to the effective date of this First Report and Order relinquish non-
compliant uses; and (2) it takes any steps necessary (for example reprogramming
switch software) to complete 311 calls from its subscribers to a requesting 311 entity in
its service area.
36. We find that use of an N11 code for access to non-emergency police
services could alleviate congestion on 911 circuits, which could permit more effective
operation of 911 emergency services. By promoting the safety of life and property,
ensuring the public prompt access to emergency services is consistent with the purpose
stated in Section 1 of the Act.174 In determining not to alter 911's designation as a
national code for emergency services, we have already noted that the use of 911 for
this purpose "clearly serves the public interest because end users know that they can
dial this code from virtually any exchange in the country in order to obtain emergency
assistance."175 Therefore, ensuring that 911 circuits are not overburdened with non-
emergency calls is also of utmost importance. Eventually, the use of a single N11 code
nationwide for non-emergency calls will let callers know that they can dial this code from
any exchange (to obtain necessary governmental services) without hampering others'
access to 911 for emergencies. We also are confident that local education programs
will help ensure that members of communities become aware of: (1) the new non-
emergency number and its primary purpose; (2) the importance of continuing to dial
911 in real emergencies; and (3) any secondary uses for the new code in the particular
jurisdiction.
37. We also leave with local jurisdictions in the first instance the discretion to
determine whether 311 should be used locally to reach other government services, as
the Department of Justice has suggested.176 Local jurisdictions can better determine
whether this code could or should be used for access to services in addition to non-
emergency police services. We find that state public utilities commissions, in
conjunction with state and local governments, can address any conflicting requests for
173 See discussion at para. 37, infra.
174 See 47 U.S.C. § 151.
175 See para. 23, supra.
176 See Department of Justice August 26, 1996 Letter.
24
use of 311 (for example situations in which city and county law enforcement agencies
both request 311 implementation in the same geographic area) better than us.
38. The record indicates that 311 is being used in several jurisdictions. Our
decision to allow other uses of the 311 code to continue for a reasonable period will
ensure that there is no unreasonably abrupt disruption of those uses. We expect that,
in ensuring relinquishment of non-compliant uses of 311 as required above, providers of
telecommunications services also ensure that this occurs with the least disruption
possible to the user's business.177 We are particularly concerned that there be no
confusion for individuals with hearing or speech disabilities who currently use 311 to
access emergency services in the State of New York. Our decision to allow non-
compliant uses to continue until six months after a request is made to use 311 for non-
emergency services in a particular jurisdiction will provide the State of New York
additional time: (1) to educate users with hearing and speech disabilities about the
future unavailability of 311 for emergency services; and (2) to ensure that 911 and other
emergency services are directly accessible by users with disabilities, as required by
regulations implementing the Americans with Disabilities Act (ADA).178
39. While we acknowledge that many commenters raise concerns about using
311 for non-emergency police calls (citing the possibility of user confusion with 911,
technical issues related to implementation, costs, funding and the potential effects on
the 911 system), we find, nonetheless, that the benefits of a national N11 assignment
for non-emergency calling in those communities choosing to use 311 will outweigh the
implementation concerns, which are most appropriately addressed by local
governments. This national assignment is intended to reduce the burden on 911
circuits, when needed, by providing an easy-to-remember number for such use. We
realize, as the National 911 Commenters assert, that not all 911 circuits are congested.
Local governments are best suited to determine the need for relief of their 911 systems
from non-emergency calling, and therefore, whether to avail themselves of the ability,
made easier by this national assignment, to request 311 implementation in their
respective jurisdictions. Several parties suggest that prior to considering 311 for non-
emergency calling, the Commission should focus on making ubiquitous 911 emergency
calling. As noted above,179 thirty years ago, AT&T designated 911 for access to
emergency services, and this First Report and Order declines to alter this designation
for 911.180 Decisions to implement 911 service continue to be made locally. We do not
require local jurisdictions to implement 911 because they are best fit, as they are with
311, to determine the need for it.
177 See para. 35, supra.
178 See 28 C.F.R. § 35.162, implementing Title II of the Americans with Disabilities Act (ADA), 42 U.S.C.
§ 12131 - 12161.
179 See footnote 12, supra.
180 See para. 23, supra.
25
40. Some of the concerns that lead certain parties to suggest alternatives to a
national N11 number for non-emergency calls, such as a three digit number without "11"
as the last two digits (such as 222), an 800 number, or a seven-digit number,181 are the
same reasons that have led us to find an N11 number superior to those alternatives:
namely, the similarity to 911. While it may be technically possible to implement the
alternatives above, the similarity between an N11 number and 911 will make the non-
emergency number both easy to remember and easy to use, thus resulting in greater
reduction of non-emergency calls on 911 emergency circuits. We are confident that, to
lessen the possibility of confusion between 311 and 911, local education programs in
jurisdictions requesting 311 service, will focus on the importance of continuing to dial
911 in real emergencies. If a local government concludes that an alternative number is
working well for non-emergency calling, it may decide not to request 311
implementation. Our assignment leaves the choice to local governments.
41. We deny requests that current non-compliant uses of 311 at the local level
be grandfathered. Grandfathering existing uses would make it impossible for a local
government, in a jurisdiction that may need to relieve overburdened 911 circuits and in
which 311 is already assigned for non-compliant uses to choose to use 311 to obtain
that relief. We note, however, that uses of 311 for other purposes prior to the effective
date of this First Report and Order may continue until the local government in that area
is prepared to activate a non-emergency 311 service. Our actions here are consistent
with existing Bellcore guidelines permitting local use of N11 codes provided that such
assignments and use can be discontinued on short notice.182 The need to provide
relief, in a timely fashion, when 911 circuits become congested with non-emergency
calls makes it unreasonable for us to defer implementation issues to industry fora.
42. States and local governments may deploy 311 through their 911 centers
or devise alternative procedures for routing and answering 311 calls. We acknowledge
that a provider of telecommunications services may incur certain costs (for example, in
reprogramming switch software) to enable implementation of 311. Since 311 calls, like
911 calls, are typically intrastate, states would regulate cost recovery in most
instances.183 Funding of 311 service also is a local issue.
181 We note that parties have expressed interest in other abbreviated dialing arrangements generally as
alternatives to N11 codes. We discuss these alternatives at para. 59-62, infra. We find that, on the
record before us, we are unable to find that the public interest supports national reservation at this time
of any alternative dialing arrangements for any particular purpose. See para. 61, infra.
182 See Network Notes, "Numbering Plan and Dialing Procedures" at 3.4.1.
183 Cf. 47 U.S.C. § 332(c)(3) (preempting state regulation of rates and entry for CMRS, but allowing the
states to petition the Commission for authority to regulate rates in limited circumstances). Section 332
provides that CMRS providers are to be treated as common carriers, but permits the Commission to
forbear from applying certain sections of Title II. Specifically, the Commission may forbear from applying
any section of Title II, except Sections 201, 202, and 208. See 47 U.S.C. § 332(c)(1)(A). In the CMRS
Second Report and Order, the Commission determined that it would be in the public interest to forbear
from imposing most Title II requirements on CMRS providers, including tariffing requirements. See
26
43. The wireless industry expresses concern about costs and other
implementation issues. CTIA,184 while supporting nationwide reservation of 311 for
non-emergency police telephone calls, contends that the Commission must define the
scope of 311 service so that CMRS providers are technically capable of providing the
service. CTIA states that the Commission should, therefore, address how calls would
be routed and terminated. CTIA emphasizes that 311 non-emergency service is
separate and distinct from 911 emergency service and argues, therefore, that carriers
should not be required to provide the same features or the same terms for 311 service
that they do for 911 emergency service (for example, carriers should be able to provide
311 service for a fee). We agree with CTIA that 311 should be used to provide a non-
emergency service that is distinct from 911 service. For this reason, it is not our
intention by this First Report and Order to impose the same types of obligations on
wireless providers with regard to 311 service as we did with regard to 911 service. 185
44. We deny GSA's request to assign an N11 code specifically for access to
federal government services. Even though they are not 911 emergency situations, we
find an element of urgency likely attaching to calls to police that is lacking when the
public is seeking access to other governmental services. There are other easily
remembered numbers available from toll free dialing codes that could give the public
prompt and easy access to services for which there is not the urgency associated with
calls to local police. We note, however, that the discretion we give local governments to
use 311 for other government service access, in addition to non-emergency police
access, grants in part NASTD's request for national assignment of an N11 code to
facilitate public access to state agencies.
Implementation of Sections 3(n) and 332 of the Communications Act, Regulatory Treatment of Mobile
Service, Second Report and Order, 9 FCC Rcd 1411, 1463-93 (1994).
184 See CTIA 311 Comments.
185 See Wireless E-911 Report and Order and FNPRM, cited at footnote 80, supra.
27
d. Access to Repair Services
(611) and Business Office Uses
(811)
45. Some LECs currently use 611 and 811 to facilitate repairs and other
customer services. Use of these two codes, however, appears to be far less ubiquitous
than use of 411 for directory assistance and 911 for emergency services. For example,
unlike 911 emergency service, LECs may use 611, 811, or other unassigned N11 codes
for other local services. Several LECs that currently use 611, 811, or both for customer
services and internal functions request that they be allowed to continue to use these
N11 codes.186 Because the record does not support reassignment of either of these
N11 codes, we conclude that these two codes may continue to be used for their present
purposes until one or both of them is needed for other national purposes.
46. With multiple LECs in the local market, access to these codes for repair
and business office uses by only one facilities-based carrier serving that market would
be anticompetitive. The possibility of anticompetitive effects is not an issue with respect
to other facilities-based carriers because 811 and 611 are only used within a carrier's
own network. Therefore, a facilities-based LEC can use one or both of these codes
even if it is already being used by another LEC. In an effort to ensure that no facilities-
based LEC gains an unfair advantage over its competitors, we conclude that: (1) all
providers of telephone exchange service, both incumbents and new market entrants,
whether facilities or non facilities-based providers of telephone exchange service,
should be enabled to use the 611 and 811 codes for repair services and business office
uses as the incumbent LECs do now; and
(2) by dialing these N11 numbers, customers should be able to reach their own carriers'
repair or business services. These conclusions are consistent with the Act's
requirement that all LECs permit competing providers of telephone exchange service
and telephone toll service to have nondiscriminatory access to telephone numbers.187
186 See, e.g., Ameritech Comments at 4; SNET Comments at 2.
187 See 47 U.S.C. § 251(b)(3). We note that the Commission, in Implementation of the Local
Competition Provisions in the Telecommunications Act of 1996, CC Docket No. 96-98, First Report and
Order, FCC 96-325 (rel. Aug. 8, 1996) (First Interconnection Order), motion for stay of the FCC's rules
pending judicial review denied, Implementation of the Local Competition Provisions in the
Telecommunications Act of 1996, CC Docket No. 96-98, FCC 96-378 (rel. Sep. 17, 1996), partial stay
granted, Iowa Utilities Board v. FCC, No. 96-3321, 1996 WL 589204 (8th Cir. Oct. 15, 1996) (Iowa
Utilities Board v. FCC) (Local Competition First Report and Order) found that CMRS providers
(specifically cellular, broadband PCS and covered SMR), in addition to meeting the statutory definition of
telecommunications carriers, also provide telephone exchange service and exchange access as defined
by the Act. This means that these CMRS providers would have nondiscriminatory access to telephone
numbers from LECs. See Local Competition First Report and Order at para. 1012-1013. The
Commission declined to treat CMRS providers as LECs at this time. See id. at para. 1004. Therefore,
the requirements imposed on LECs in Section 251(b)(3) do not apply to CMRS providers.
28
e. Directory Assistance (411)
47. Like 911 for access to emergency services, 411 has long been assigned
for access to local directory assistance services. Because directory assistance queries
are often made while travelling away from one's regular residence or place of business,
a short, easy-to-recall, uniform nationwide code would be very useful for obtaining
telephone numbers. For these reasons, we find continued use of 411 to call local
directory assistance services justified by public convenience and necessity.
Accordingly, as we proposed in the N11 NPRM, we do not alter the assignment of the
411 code. The number 555-1212, like 411, is a nationally-recognized number for
directory assistance.188 U S WEST, in its comments, noted:
The 555 central office code, or prefix, is generally used for access to LEC
directory assistance services. Typically, an end user dials 1+555-1212 to
reach his/her LEC's 'local' directory assistance service. For directory
assistance for an area code different than the area code from which the
call originates . . . the end user dials 1-[area code]-555-1212.189
U S WEST suggests expanding the 555 prefix to information service providers. U S
WEST suggests that "to avoid potential conflicts with existing directory assistance
services, it might be useful to reserve the 555-1XXX series of numbers for directory
information and related services."190 The Commission, in the recent Local Competition
Second Report and Order, concluded that no Commission action was necessary "with
respect to the ability of customers to reach directory assistance services through 411 or
555-1212 arrangements"191 and decided not to require any alternatives to these two
codes for access to directory assistance. By concluding here that the assignment of
411 for such local services should continue, we do not intend to foreclose the use of
555-XXXX or any other dialing arrangements for such services.
48. In view of reports that some LECs were planning to use 411 for new
information service offerings that would be classified as enhanced services under our
rules,192 the N11 NPRM sought comment on whether LEC use of 411 should be
restricted to the provision of traditional directory assistance services.193 Several
188 See Local Competition Second Report and Order at para. 149.
189 U S WEST Comments at 13.
190 Id. at 14.
191 Id. at 151.
192 See footnote 8, supra, for a definition of "enhanced services."
193 See N11 NPRM at para. 11. By "traditional" directory assistance services we refer to operator
provision of local telephone numbers. The Commission has determined that traditional directory
assistance services are "adjunct" to basic services and are regulated pursuant to Title II of the
Communications Act. See Amendment of Section 64.702 of the Commission's Rules and Regulations,
29
commenters argue that we should link a decision to allow a particular LEC to provide
enhanced services through 411 with a decision to direct assignment of N11 codes to
information service providers competing with that LEC.194 Others argue that 411 should
always be restricted to basic directory assistance.195 While we encourage LECs to
expand the range of services they offer to the public, we recognize the possible
competitive advantage that LECs would be given if they were able to use N11 codes for
their enhanced services offerings. We conclude, therefore, that a LEC may not itself
offer enhanced services using a 411 code, or any other N11 code, unless that LEC
offers access to the code on a reasonable, nondiscriminatory basis to competing
enhanced service providers in the local service area for which it is using the code to
facilitate distribution of their enhanced services.196 LECs offering enhanced services
through the use of an N11 code are subject to rules designed to protect against
discrimination and possibly other anticompetitive conduct.197 Moreover, the Bell
Operating Companies (BOCs) are subject to additional safeguards pursuant to
Computer III.198 For example, BOCs offering such services today must file and receive
approval of comparably efficient interconnection (CEI) plans.199 Such measures will
help ensure that competing enhanced service providers will have access to basic
transmission facilities on an unbundled and functionally equivalent basis. 200 These
77 FCC 2d 384 at para. 421 (1980) (Computer II), modified on recon, 84 FCC 2d 50 (1980) (Computer II
Reconsideration Order), modified on further recon., 88 FCC 2d 512 (1981) (Computer II Further
Reconsideration Order), aff'd sub nom., Computer and Communications Industry Assoc. v. FCC, 693
F.2d 198 (D.C. Cir. 1982), cert. denied, 461 U.S. (1983).
194 See, e.g., Ameritech Comments at 3; Pacific Comments at 4; USTA Comments at 30.
195 See, e.g., Mobile Comments at 2.
196We note that the Commission has established its ancillary jurisdiction over enhanced services in its
Computer II decision. See Computer II at paras. 124-125.
197 See, e.g., Computer II at para. 231.
198 See Amendment of Section 64.702 of the Commission's Rules and Regulations (Computer III), CC
Docket No. 85-229, Phase I, 104 FCC 2d 958 (1986) (Phase I Order), recon., 2 FCC Rcd 3035 (1987)
(Phase I Recon. Order), further recon., 3 FCC Rcd 1135 (1988) (Phase I Further Recon. Order),
second further recon., 4 FCC Rcd 5927 (1989) (Phase I Second Further Recon.), Phase I Order and
Phase I Recon. Order vacated, California v. FCC, 905 F.2d 1217 (9th Cir.1990) (California I); Phase II, 2
FCC Rcd 3072 (1987) (Phase II Order), recon., 3 FCC Rcd 1150 (1988) (Phase II Recon. Order), further
recon., 4 FCC Rcd 5927 (1988) (Phase II Further Recon. Order), Phase II Order, vacated, California v.
FCC, 905 F.2d 1217 (9th Cir.1990); Computer III Remand Proceedings, 5 FCC Rcd 7719 (1990) (ONA
Remand Order), recon., 7 FCC Rcd 909 (1992), pets. for review denied, California v. FCC, 4 F.3d 1505
(9th Cir.1993) (California II); Computer III Remand Proceedings: Bell Operating Company Safeguards
and Tier 1 Local Exchange Company Safeguards, 6 FCC Rcd 7571 (1991) (BOC Safeguards Order);
BOC Safeguards Order vacated in part and remanded, California v. FCC, 39 F.3d 919 (1994) (California
III).
199 See, e.g., Bell Operating Companies Joint Petition for Waiver of Computer II, 10 FCC Rcd 13758
(Com. Car. Bur. 1995).
200 See Phase I Order at para. 147.
30
conclusions are also consistent with the Act's requirements that all LECs permit
competing providers of telephone exchange service and telephone toll service to have
nondiscriminatory access to directory assistance and to telephone numbers, 201 and that
BOCs, before they are permitted to offer in-region, interLATA services, must show that
the access or interconnection they offer to other telecommunications carriers includes,
among other things, nondiscriminatory access to directory assistance services. 202
f. Access to Telecommunications Relay Services
49. Background. NCLD's petition requests that two N11 numbers be assigned
or reserved for TRS access.203 It states that under the ADA, common carriers are
required to provide TRS, a telephone transmission service designed to provide persons
with speech or hearing disabilities functionally equivalent access to the telephone
network.204 NCLD argues that assignment of N11 numbers will facilitate TRS access
and thus further the goals of the ADA. NCLD states that variations among and within
states in the TRS numbers assigned make access to the relay service confusing and
difficult. NCLD also states that access can be especially difficult for TTY 205 users
because they cannot directly call directory assistance, and thus cannot easily determine
the local relay number. In addition, NCLD argues that an N11 number would
significantly reduce the number of digits that must be dialed when placing a relay call.
NCLD explains that many relay centers have an eleven digit 800 number, and that as
many as twenty-one digits (eleven to reach the relay center, and ten to reach the final
destination) may be needed to complete a call. Finally, NCLD notes that while a
majority of states use two numbers for relay access, one for access by TTY users and
one for access by voice users, approximately seventeen states use only one number for
both TTY and voice callers.
201 See 47 U.S.C. § 251(b)(3). See footnote 164, supra, for a discussion of the application of this
provision of the Act to CMRS providers.
202 47 U.S.C. § 271(c)(2)(B)(vii)(II).
203 TRS allows people with hearing or speech disabilities to use the telephone. TRS facilities are
equipped with specialized equipment and staffed by communications assistants who relay conversation
between people who use text telephones and people who use traditional telephones. The Commission
issued a Notice of Inquiry (NOI) seeking comment on TRS issues in Telecommunications Relay
Services, the Americans with Disabilities Act of 1990, and the Telecommunications Act of 1996, Notice
of Inquiry, CC Docket No. 90-571, FCC 97-7, ___ FCC Rcd. ___, (Released January 14, 1997) (TRS
NOI). This TRS NOI, states that it will not include consideration of assignment of N11 numbers to
access TRS because that issue is pending before the Commission and will be addressed in this
proceeding. See id. at n. 6.
204 See 47 U.S.C. § 225(a)(3), (c).
205 TTY is a teletypewriter, which is a device for communicating alphanumeric information over
telecommunications networks.
31
50. Comments. Most commenters support reservation or assignment of a
nationwide N11 code for TRS access. Commenters agree that a uniform N11 code will
reduce confusion, provide quicker dialing and promote TRS use.206
51. States filing comments generally support assignment of nationwide N11
codes for TRS access.207 In particular, the Attorney General of the State of Illinois
(Illinois) supports the allocation of both 711 and a second N11 number to access TRS
on a nationwide basis.208 Texas, relying on the ADA, states that it believes that a
nationwide assignment of N11 codes for TRS is appropriate.209 The Florida Public
Service Commission (Florida), however, while noting that it does not oppose the
assignment of 711 and the use of another N11 code for access to TRS systems,
observes that its investigation of the use of N11 codes, in which it decided not to
reserve N11 codes for TRS access, has revealed that "other numbers such as 555-
XXXX or 1-800-XXX-XXXX could be better suited and more easily converted to TRS
access."210 Florida asserts that any Commission rulemaking should "address N11
access in comparison with other potential access arrangements . . . ." 211
52. LECs generally favor reservation of a single N11 code for TRS access, but
question whether an N11 assignment is appropriate at this time.212 Commenters
supporting an N11 reservation, rather than assignment, generally argue that a number
of policy and technical issues must be resolved before a nationwide N11 code for TRS
can be implemented.213 Bell Atlantic states that a dialing arrangement that
automatically routes all TRS callers to a single TRS provider would place other TRS
providers at a competitive disadvantage.214 GTE warns that a "flashcut" to N11 access,
on either a nationwide or statewide basis, would require a heavy commitment of
resources, would be difficult to coordinate, and would create network problems during
206 See, e.g., Louisiana Relay Comments at 1; Leigh Comments at 1; Life After Deafness/California
Comments at 1; Gallaudet/Kapi'olani Comments at 1. Comments and reply comments cited in
paragraphs 30-36 are responding to the NCLD petition.
207 See, e.g., Oregon Public Utility Commission Comments at 1; Attorney General of the State of Illinois
Comments at 1; State of Texas Comments in response to Emergency Petition for Rulemaking by
National Center for & Deafness and Telecommunications for the Deaf, Inc (hereinafter NCLD/TDI
petition) at 3.
208 Illinois Comments at 1.
209 Texas Comments in response to NCLD/TDI petition at 3.
210 Florida Reply Comments at 3.
211 Id.
212 See U S WEST Comments at 3-4.
213 See, e.g., SWBT Comments at 1-7; U S WEST Comments at 3-4.
214 Bell Atlantic Comments at 4.
32
implementation and testing.215 GTE suggests that industry fora could resolve technical
issues and could establish a state by state schedule for implementation.216
53. Noting that N11 codes are a scarce resource, several parties suggest
alternative solutions such as a uniform nationwide 800 number, 555-XXXX number, or
950-XXXX number for TRS access. Cox contends that technical and operational issues
render N11 numbers unsuitable for providing uniform access to relay service in the near
future.217 Cox, in its December 12, 1995, ex parte presentation, reiterated its position
that there should be no N11 numbers reserved for national use for access to TRS. 218
Cox presented three general reasons for its position: (1) N11 cannot provide "ubiquity"
in that it would not be possible to make the code available to all subscribers, regardless
of their location; (2) N11, because of the needed modifications in switches around the
country, is too expensive for such a non-commercial use; and (3) N11 is best suited for
purely local services because, for example, current network architectures support such
use, and there are no comparable resources available for local services. Cox asserts
that 800 service would and should be made available for TRS access. Cox notes that
800 service is designed for regional and nationwide coverage. It asserts that,
especially with 800 number portability, a national 800 number for TRS access would be
ubiquitous and much less expensive than an N11 number. U S WEST asserts that "it is
clear that not all U S WEST end offices have the capability to replace the current 800
numbers [through which it accesses service arrangements to route TRS calls] with a
711 telephone number."219 U S WEST suggests that, until technical issues are
resolved, "the industry should promote the deployment of a single national 800
telephone number that can direct calls to the nearest TRS bureau." 220 It asserts that
with a national 800 number using geographic routing, each originating call would go to
the nearest TRS provider. As noted above, Florida, while stating that it does not
oppose the assignment of 711 and the use of another N11 code for access to TRS
systems, suggests the need for a Commission investigation into alternatives to an N11
code, such as an 800 number.221
54. Other parties, however, assert that an 800 number, necessitating dialing
many digits, is not a viable alternative to an N11 number for TRS access. Illinois, for
example, states that an 800 number necessitates dialing 17 digits, thus doubling the
215 GTE Reply Comments at 9.
216 GTE Comments at 9.
217 Cox Reply Comments at 3-6.
218 Cox December 12, 1995 Ex parte Presentation.
219 U S WEST Comments at 5.
220 Id. at 7.
221 Florida Reply Comments at 3.
33
length of time to dial, and adds that currently each state has one or more different
telephone numbers to access TRS. Illinois asserts that the existence of multiple
numbers may pose difficulties for those travelling to various states:
In Illinois, for example, voice users and TTY users of the TRS must dial
one of two 1-800 numbers to access TRS. If a person who is severely
hard of hearing, deaf, or has speech disabilities travels from another state
to Illinois and attempts to make a telephone call using TRS, he/she must
know the 1-800 number or know someone who knows the number or must
have access to a current telephone book, because one can only reach
directory assistance (411) through the relay service, not directly by TTY.
This is especially frustrating for those who travel to many different
states.222
The State of Wisconsin, Department of Health and Social Sciences (Wisconsin), in
advocating reservation of an N11 number for TRS, expresses concern that currently
"deaf/hard of hearing and speech impaired users of the relay [service] must dial a 11-
digit (800) number to access the service, then enter the 7 or 10-digit number they wish
to call."223 According to Wisconsin, this necessity fails to provide "equal access in
telecommunications." The Triangle Association of the Deaf (Triangle) notes a similar
problem with the use of 1-800 numbers for access to TRS: "often more than 17
numbers must be dialed before reaching the called party, which can double the length
of time on the line needed to dial for relay users."224 NCLD, in its reply comments,
refers to the Commission proceeding that resulted in its July 26, 1991 issuance of rules
implementing title IV of the ADA. Those rules imposed minimum guidelines regarding
TRS service:
[i]ncluded within the reply comments of [over 70 organizations submitting
comments to the FCC] was a request that access to relay services be
made available through a single 800 nationwide telephone number set
aside through the North American Numbering Plan. The Commission
responded that because 800 numbers are assigned to particular carriers,
it did not find it feasible to establish a single, nationwide relay number at
that time. Nevertheless, even then, the Commission recognized the
benefits of a universal number: 'We encourage state systems and all other
relay providers to use numbers that are easy for consumers to remember
and would further the goal of nationwide access . . . .'225
222 Illinois Comments at 2.
223 Wisconsin Comments at 1.
224 Triangle Comments at 1.
225NCLD Comments at 8, note 6, quoting Telecommunications Services for Individuals with Hearing and
Speech Disabilities, and the Americans with Disabilities Act of 1990, Report and Order and Request for
Comments, CC Docket No. 90-571 at para. 42.
34
55. Discussion. We conclude that an N11 code, specifically 711, should be
assigned for TRS use. We agree with parties asserting that certain issues related to
technical and operational capability, cost, and competition, must be resolved before a
nationwide N11 code for TRS access can be implemented. We address such issues in
the FNPRM. We tentatively conclude that nationwide implementation of 711 for TRS
access should occur within three years of the effective date of this First Report and
Order and we seek comment on this proposal. Three 800-855-XXXX numbers have
been allocated for TRS access by the Industry Carriers Compatibility Forum (ICCF) of
the Alliance for Telecommunications Industry Solutions.226 In the FNPRM, we state that
we do not anticipate any conflict between allowing activation of the 800-855-XXXX
numbers and the later implementation of a 711 code for access by individuals with
hearing or speech disabilities to TTY. The 711 code, unlike the 800 codes, will support
three digit access to TTY by people with hearing or speech disabilities. We believe this
offers distinct advantages to such persons for whom, as commenters note, the time on
the line before reaching the called party would possibly be doubled due to the number
of digits that access through an 800 number would require. A nationwide N11 code
would also eliminate the current need for TRS users travelling from state to state to
remember different lengthy 800 numbers for each state.
56. An N11 code may significantly facilitate TRS access, thus furthering the
goals of both the 1996 Act227 and the ADA. In particular, a nationwide N11 code will
significantly reduce the number of digits that must be dialed when placing a relay call,
and will eliminate the problem of determining the appropriate local relay number. We
also note that most commenters agree that assignment of an N11 code for TRS is in the
public interest. Because N11 codes are a scarce resource, and because many states
already provide TRS access for both TTY and voice users through a single number, we
conclude that only one N11 number should be used for TRS. Moreover, because
Hawaii and Canada already use 711 for TRS access, and because uniformity would
facilitate access to TRS, we conclude that 711 is the most appropriate code to support
TRS access. We, therefore, determine that 711 should be assigned as a national code
for TRS use, and we direct Bellcore, in its capacity as NANP administrator, to assign
711 for such use as of the effective date of this First Report and Order.
226 The entire 855 "NXX" code, within the 800 area code, has been reserved for disability access. NXX
refers to the first three digits of a North American local telephone number and identifies the local central
office. N represents any digit from 2 to 9 and X is any digit. Of the approximately ten thousand numbers
associated with this NXX code, three have been specifically reserved by the industry for access by
persons with speech or hearing disabilities.
227 The Act requires that telecommunications services, telecommunications equipment, and customer
premises equipment be accessible to persons with disabilities, if readily achievable. The duty to ensure
accessibility is imposed on: (1) telecommunications service providers regarding their services; and (2)
equipment manufacturers regarding their telecommunications equipment and customer premises
equipment. See 47 U.S.C. § 255. The Commission released a Notice of Inquiry on September 19, 1996,
beginning the Commission's implementation of Section 255. See In the Matter of Implementation of
Section 255 of the Telecommunications Act of 1996, Notice of Inquiry, WT Docket No. 96-198, FCC 96-
382, 61 Fed. Reg. 50465 (September 26, 1996) (Section 255 NOI).
35
4. Statutory Preemption
57. The Act gives the Commission exclusive jurisdiction over numbering in the
United States.228 Because the Commission's jurisdiction is exclusive, the states have
no authority to permit the use of N11 codes in a manner inconsistent with the
conclusions reached in this First Report and Order. As noted above, the release of the
N11 NPRM and the filing of the comments and replies all occurred prior to enactment of
the 1996 Act amendments to the 1934 Act. Insofar as they discuss the issue of
preemption, therefore, they have become moot.229
58. Moreover, we find that a nationwide, uniform system of numbering is
essential to the efficient delivery of interstate and international telecommunications. 230
Despite the fact that most individual N11 calls are likely to be intrastate, N11 numbers,
like 911, have significance that go beyond state boundaries. At times, an end user who
is travelling can dial the same N11 code used at home to access the same service
accessed at home. In order to achieve the maximum public benefit from the allocation
of particular codes to certain services, those codes must be allocated in a consistent
manner on a nationwide basis.
5. Other Issues
a. Alternate Abbreviated Dialing Arrangements
59. Background. In the N11 NPRM, the Commission stated that other
abbreviated dialing arrangements, such as "XX#" or "*XX", might accommodate many
times the number of providers that N11 service codes could serve. 231 We said that
using these arrangements, however, might require substantial time to implement and be
expensive. For example, if "#" were required in an abbreviated dialing arrangement,
dialing could not occur from millions of rotary telephones still in service. Moreover, "#"
and "*" are used today to activate switch capabilities, not for customer dialing. It is
228 See 47 U.S.C § 251(e)(1).
229 Few commenters addressed the preemption issue directly. The State of Texas noted that the FCC
does not have general preemptive authority over the assignment of N11 codes used for "purely intrastate
uses" but conceded that Title IV of the ADA provides authority for the "FCC to require the uses of a
particular N11 code for access to interstate relay programs and to condition approval of state programs
on the use of the same code." See Texas Comments in response to NCLD/TDI petition at 3, citing 47
U.S.C. §§ 225(b)(2), (c)(2), (d).
230 See NANP Order at para. 26; Ameritech Order at para. 13.
231 See N11 NPRM at para. 19. By "alternate dialing arrangements," we mean arrangements other than
the conventional seven and ten digit sequences that facilitate recall and use by the general public.
"Abbreviated dialing arrangements" are alternate dialing arrangements that involve less than seven and
usually four or fewer dialing digits."xx#" is an example where "X" may be any number from 0 to 9.
36
noteworthy, however, that with CLASS services, if it is not possible to use "*XX" dialing,
for example with a rotary telephone, "11XX" is an alternative abbreviated dialing
arrangement.232 The N11 NPRM invited comment on the feasibility of requiring
abbreviated dialing arrangements to be made quickly available in lieu of or in addition to
requiring exchange carriers to make N11 codes available.
60. Comments/Discussion. The record shows that there is considerable
interest in alternative abbreviated dialing arrangements.233 Some commenters seek
abbreviated numbers in only one local calling area,234 while others seek a uniform
abbreviated number for an entire state, a region, or the whole country. 235 Commenters
suggest using numbers with two to four digits plus a "*" or a "#", such as *XX or NXX#.
One commenter suggests codes with "**X."236
61. We conclude that abbreviated dialing could clearly serve many useful
purposes and we urge industry fora to continue to explore the feasibility of their use.
When those entities identify abbreviated dialing arrangements that would be practical,
both economically and technically, we encourage them to develop reasonable
guidelines for the implementation and allocation of the related numbers. In addition, we
ask the NANC to explore how rapidly abbreviated dialing arrangements could be
deployed and to report back to the Commission on this issue. On the record before us,
however, we are unable to find that the public interest supports national reservation at
this time of any alternative dialing arrangements for any particular purpose, except as
previously described in this First Report and Order.
62. While we decline to make any national assignment or other reservation of
abbreviated dialing arrangements at this time, we reiterate that no federal policy bars
the use of such arrangements for intrastate service offerings.
b. Recall Procedures
63. Background/Comments. In the N11 NPRM, the Commission solicited
comment on methods for recalling N11 service codes and any notice periods that
should precede such recalls.237 Several commenters express concern that this
232 CLASS is a set of calling party number (CPN)-based services, such as caller ID, auto call return,
selective call forwarding and other services.
233 See, e.g., Alternative Newspapers Comments at 4; Cox Comments at 4; Advance Reply Comments
2; Cox Reply Comments at 29.
234 See, e.g., Cox Comments at 4.
235 See, e.g., Mobile Comments at 3; MCI Reply Comments at 7.
236 PBS/PG Comments at 3.
237 N11 NPRM at para. 13.
37
Commission or state commissions will be unable to recall on short notice those N11
codes that have been made available for local uses.238 They request establishment of
specific time periods and other procedures for recall to avoid any unreasonable delay if
the public convenience and necessity requires that assigned N11 codes be used for
other purposes.
64. Discussion. We believe it unnecessary to adopt specific rules for future
recall of N11 codes at this time. First, widely distributed industry numbering documents
consistently and unambiguously state that an N11 code assignment is not a permanent
assignment and is subject to termination on short notice.239 Second, when state
commissions have allowed N11 use, their authorization orders, which, by the terms of
the Commission's Local Competition Second Report and Order remain in effect,240
consistently state that such use is subject to termination or other modification on short
notice, typically six months.241 If an N11 assignee is unable or unwilling to cooperate in
a national recall of an N11 code, we would not hesitate to order termination of the
switching services necessary to the functioning of that N11 code or to take other action
required to make the N11 code available for other purposes. In the event of a national
recall, the Commission will take such action as necessary to give interested parties
sufficient notice of the recall and an opportunity to be heard on how the recall should be
enforced. Moreover, as the time needed for code relinquishment could vary depending
on the use of codes in question, parties will further be given an opportunity to address
the network, customer, and administrative concerns that affect recall.
238 See, e.g., SWBT Comments at 9-10.
239 See Network Notes. "Numbering Plan and Dialing Procedures" at 3-8. As stated above, Network
Notes does not define short notice.
240 See para. 13, supra.
241 See, e.g., Request for Approval of Tariff Filing to Introduce N11 Service, Order Regarding N11
Abbreviated Dialing, Docket No. 920962-TL, Florida Public Service Commission, Nov. 4, 1993 (noting
that Southern Bell's tariff clearly states that any and all N11 codes could be recalled by the NANP at any
time, and if so, must be relinquished within six months).
38
6. Regulatory Flexibility Act
65. See Appendix E, infra, for the Final Regulatory Flexibility Analysis.
IV. FURTHER NOTICE OF PROPOSED RULEMAKING
A. Introduction
66. The proposals below, and the comments we seek regarding them, are part
of our analysis of the Commission's role with respect to numbering administration. The
guiding principal shaping these proposals is that a uniform numbering plan is an
essential prerequisite to an integrated public switched telephone network. There must
be a single, consistent set of numbering principles allowing all switching equipment
connected to the network to route every call to its correct destination. Concomitant with
the need for one uniform numbering plan is the imperative that any numbering plan be
capable not only of serving incumbents, but also of accommodating new market
entrants. For this reason, we have attempted, wherever possible, to ensure that new
telecommunications carriers have access to numbering resources on the same basis as
incumbents.
B. Access to Telecommunications Relay Services
67. While we believe that an N11 code to support nationwide TRS access is in
the public interest, it is not clear, as several commenters note, whether it is technically
feasible to implement such a code at this time.242 We specifically request parties to
address whether there can be nationwide implementation of an N11 code and how to
address less than nationwide implementation, if network facilities of some
telecommunications carriers preclude use of N11 for TRS access. Parties should also
address the following issues:
(1) how competition among relay providers would be maintained; (2) whether
implementation is technically feasible and, if so, the details of such implementation; (3)
the projected costs of implementation and how those costs should be recovered; and
(4) what effect, if any, nationwide implementation of an N11 code for TRS access will
have on CMRS providers and their networks.
68. We tentatively conclude that nationwide implementation of 711 for TRS
access should occur within three years of the effective date of the First Report and
Order and we seek comment on this proposal. Sprint, we note, has projected this as a
reasonable timeframe for switched-based N11.243 We understand switched-based N11
242 For example, there are technical issues associated with the switch modifications necessary to route
N11 calls on a local basis. Configuring the dialing arrangements to enable relay service users to choose
interexchange carriers is another technical issue.
243 Switched-based N11 is only one example of an architectural arrangement supporting the use of N11.
Another example may be an arrangement using intelligent network capabilities.
39
in the context of TRS to mean that the N11 dialing information would be stored in the
switch, and when TRS users in a calling area dial the N11 code, the
telecommunications carrier's end office switch would automatically route the call to the
relay center. We understand from Sprint that such implementation may not permit end
users to select a preferred TRS provider.244 We ask that interested parties comment on
what steps must be taken to ready the network for use of 711 as the TRS code and
whether these steps can be completed in the three year timeframe or perhaps even
sooner. We ask parties addressing implementation issues to present a timeline for
completion of steps they foresee as necessary to introduce 711. We also ask parties if
it would be possible to develop within a reasonable time an N11 "gateway" offering
access to multiple TRS providers. With such a gateway, a database query would be
launched, and parties would be able to select their TRS providers, or parties would have
their calls routed to a presubscribed TRS provider. In addition, we request comment on
whether any other important disability services could be accessed through the same
gateway and whether such a gateway would be consistent with Section 255 of the
Act.245 We request comment on whether, with such gateway access, TRS calls would
still be answered within our mandatory minimum standards for TRS answer times,
which require 85% of calls to be answered within 10 seconds.246 Finally, we request
comment from interested parties, particularly TRS providers, about the possibility of
providing both voice and text TRS services through the same abbreviated N11 code.
C. Sale or Transfer of N11 Codes
69. Background. In the N11 NPRM, the Commission identified the extremely
limited number of service codes available in each geographic area. The Commission
stated that because these codes may acquire some value, holders of these codes may
wish to sell or transfer their numbers to others.247 Accordingly, the Commission sought
comment on whether N11 codes should be permitted to be sold or transferred.248
70. Comments. Most commenters oppose the transfer or sale of N11
numbers.249 They argue that the assignment of a public resource, such as N11 codes,
244 Sprint Ex Parte presentation of July 24, 1995.
245 This section of the Act requires that telecommunications services, telecommunications equipment,
and customer premises equipment be accessible to persons with disabilities, if readily achievable. The
duty to ensure accessibility is imposed on: (1) telecommunications service providers regarding their
services; and (2) equipment manufacturers regarding their telecommunications equipment and customer
premises equipment. See 47 U.S.C. § 255. The Commission has begun implementing Section 255.
See Section 255 NOI, cited at footnote 204, supra.
246 See 47 C.F.R. § 64.604(b)(2).
247 N11 NPRM at para. 15.
248 Id.
249 See, e.g., AT&T Comments at 7; U S WEST comments at 21.
40
does not confer property rights upon the assignee.250 Some commenters support the
transfer or sale of N11 codes, but urge the Commission to develop and enforce rules
regarding such transfers and that the transfer or sale be limited to companies that
merge or are acquired.251
71. Discussion. The Commission has stated that carriers do not "own" codes
or numbers but rather administer their distribution for the efficient operation of the public
switched telephone network.252 The Commission, also on several occasions, has
further characterized telephone numbers as a national public resource. 253 Based on our
review of the record, we tentatively conclude that N11 codes should not be transferred
or sold through private transactions at this time. N11 codes are not only essential public
resources that serve important national and state goals, but are also much more scarce
than other codes. Parties are asked to comment on our statutory authority to sell the
right to use N11 codes. We also ask parties to distinguish statutory authority to sell the
right to use N11 codes from the right to sell other abbreviated dialing arrangements.
D. Administration of N11 Codes
72. As stated above, prior to enactment of the 1996 Act amendments to the
1934 Act, Bellcore, the states, the incumbent LECs, and the Commission each
performed functions relating to the administration of N11 codes. Since the AT&T
divestiture, Bellcore has served as the administrator of the NANP. Bellcore has
assigned N11 codes at the national level. In addition, the Commission may direct
Bellcore to assign an N11 code for national use if the Commission determines that such
a national assignment is in the public interest.
73. Bellcore, in its role as NANP administrator, has issued specific guidelines
addressing the use of N11 codes.254 These guidelines permit local use of N11 if such
assignments and use can be discontinued on short notice.255 In states where N11
250 See, e.g., Sprint Reply Comments at 7; USTA Comments at 19-20, 31.
251 See, e.g., Rochester Comments at 4; Mobile Comments at 4; Mtel Comments at 7;
252 See The Need to Promote Competition and Efficient Use of Spectrum for Radio Common Carrier
Services, Memorandum Opinion and Order, 59 Rad. Reg. (P&F)1275,1284 (1986). We note that
Bellcore, as current administrator of the NANP, also has characterized numbers as a public resource
and has specifically rejected that the assignment of a number implies ownership by either the assignor or
assignee. See Personal Communications Services N00 NXX Code Assignment Guidelines, Para. 2.10
(April 8, 1995 Revision).
253 See, e.g., NANP Order at para. 4 (stating that telephone numbers are a public resource); The Need to
Promote Competition and Efficient Use of Spectrum for Radio Common Carrier Services, Declaratory
Ruling, 2 FCC Rcd 2910, 2912 (1987), recon., 4 FCC Rcd 2369 (1989) (stating that NXX codes are a
national resource).
254 See Network Notes "Numbering Plan and Dialing Procedures."
255 Id.
41
codes have been used locally, state public utilities commissions have directed the LECs
to assign and administer these codes. The specific procedures for assignment of N11
codes for local use vary from state to state. Three local N11 codes have been assigned
for particular uses in at least some LEC service areas (411 for local directory
assistance; 611 for LEC repair service; and 811 for LEC business office use).
74. As part of our analysis of the Commission's role with respect to numbering
administration, we seek comments below on issues related to administration of N11
codes. The Commission had already embarked on an extensive analysis of its role with
respect to numbering prior to enactment of the 1996 Act amendments to the 1934 Act.
The Commission, in adopting a new model for administration of the NANP in the NANP
Order, decided not only that the NANP administrator's existing functions will be
transferred to a neutral entity to be recommended by the NANC, but also that "the
functions associated with CO code administration shall be transferred from the LECs to
the new NANP administrator no more than 18 months after the transfer of the existing
NANP administrative functions from Bellcore to the new administrator has been
completed."256
75. We propose that the administration of N11 codes for local use, to the
extent that this administration was done by the incumbent LECs prior to enactment of
the 1996 Act amendments to the 1934 Act, and would otherwise continue under the
terms of this First Report and Order and the Commission's Local Competition Second
Report and Order, should instead be transferred from the incumbent LECs to the neutral
NANP administrator to be recommended by the NANC. We propose that the transfer
occur with the transfer of the functions associated with CO Code administration. 257 We
seek comment on our proposal.
E. Procedural Matters
1. Ex Parte Presentations
76. This is a non-restricted notice-and-comment rulemaking proceeding. Ex
parte presentations are permitted, except during the Sunshine Agenda period, provided
that they are disclosed as provided in the Commission's rules. See generally 47 C.F.R.
§§ 1.1202, 1.1203, 1.1206. Written submissions, however, will be limited as discussed
below.258
256 NANP Order at para. 115.
257 The Commission did not intend to limit the functions to be transferred to the new entity to those
specifically listed in the NANP Order. The Commission stated there that it seeks recommendations from
the NANC on several issues, one of which is "[w]hat number resources, beyond those currently
administered by Bellcore, as the NANP administrator, should the new NANP administrator administer?"
Id. at para. 118.
258 See paras. 78-80, infra.
42
2. Regulatory Flexibility Act
77. See Appendix F, infra for the Initial Regulatory Flexibility Analysis.
F. Comment Filing Procedures
78. General Requirements. Pursuant to applicable procedures set forth in
sections 1.415 and 1.419 of the Commission's rules, 47 C.F.R. §§ 1.415, 1.419,
interested parties may file comments on or before March 31, 1997, and reply comments
on or before April 30, 1997. To file formally in this proceeding, you must file an original
and twelve copies of all comments, reply comments, and supporting comments. If you
want each Commissioner to receive a personal copy of your comments, you must file an
original and 16 copies. Comments and reply comments should be sent to Office of the
Secretary, Federal Communications Commission, 1919 M Street, N.W., Room 222,
Washington, D.C. 20554, with a copy to Janice Myles of the Common Carrier Bureau,
1919 M Street, N.W., Room 544, Washington, D.C. 20554. Parties should also file one
copy of any documents filed in this docket with the Commission's copy contractor,
International Transcription Services, Inc., 2100 M Street, N.W., Suite 140, Washington,
D.C. 20037. Comments and reply comments will be available for public inspection
during regular business hours in the FCC Reference Center, 1919 M Street, N.W.,
Room 239, Washington, D.C. 20554.
79. Other requirements. In order to facilitate review of comments and reply
comments, both by parties and by Commission staff, we require that comments be no
longer than seventy-five (75) pages and reply comments be no longer than thirty-five
(35) pages, including exhibits, appendices, and affidavits of expert witnesses. Empirical
economic studies and copies of relevant state orders will not be counted against these
page limits. These page limits will not be waived and will be strictly enforced.
Comments and reply comments must include a short and concise summary of the
substantive arguments raised in the pleading. Comments and reply comments must
also comply with Section 1.49 and all other applicable sections of the Commissions
rules.259 We also direct all interested parties to include the name of the filing party and
the date of the filing on each page of their comments and reply comments. Comments
and reply comments also must clearly identify the specific portion of this Notice of
Proposed Rulemaking to which a particular comment or set of comments is responsive.
If a portion of a party's comments does not fall under a particular topic listed in the
outline of this Notice, such comments must be included in a clearly labelled section at
the beginning or end of the filing. Parties may not file more than a total of ten (10)
pages of ex parte submissions, excluding cover letters. This 10 page limit does not
include: (1) written ex parte filings made solely to disclose an oral ex parte contact; (2)
259 See 47 C.F.R. § 1.49. We require, however, that a summary be included with all comments and reply
comments, although a summary that does not exceed three pages will not count towards the 75 page
limit for comments or the 35 page limit for reply comments. The summary may be paginated separately
from the rest of the pleading (e.g., as "i, ii"). See 47 C.F.R. § 1.49.
43
written material submitted at the time of an oral presentation to Commission staff that
provides a brief outline of the presentation; or (3) written material filed in response to
direct requests from Commission staff. Ex parte filings in excess of this limit will not be
considered as part of the record in this proceeding.
80. Parties are also asked to submit comments and reply comments on
diskette. Such diskette submissions would be in addition to and not a substitute for the
formal filing requirements addressed above. Parties submitting diskettes should submit
them to Gloria Shambley of the Common Carrier Bureau, Network Services Division,
2000 M Street, N.W., Room 235, Washington, D.C. 20554. Such a submission should
be on a 3.5 inch diskette formatted in an IBM compatible form using MS DOS 5.0 and
WordPerfect 5.1 software. The diskette should be submitted in "read only" mode. The
diskette should be clearly labelled with the party's name, proceeding, type of pleading
(comment or reply comments) and date of submission. The diskette should be
accompanied by a cover letter.
V. ORDERING CLAUSES
81. Accordingly, IT IS ORDERED, pursuant to Sections 1, 4(i), 201-205 and
251(e)(1) of the Communications Act of 1934, as amended, 47 U.S.C. §§ 151, 154(i),
201-205, and 251(e)(1), that the First Report and Order is hereby ADOPTED.
82. IT IS FURTHER ORDERED, that Bellcore, as the NANP administrator,
shall assign 711 as a national code for TRS use as of the effective date of this First
Report and Order, as discussed in this First Report and Order.
83. IT IS FURTHER ORDERED, that Bellcore, as the NANP administrator,
shall assign 311 as a national code for access to non-emergency police and other
government services as of the effective date of this First Report and Order, as
discussed in this First Report and Order.
84. IT IS FURTHER ORDERED, that when a provider of telecommunications
services receives a request from an entity to use 311 for access to non-emergency
police and other government services in a particular jurisdiction, it must ensure that,
within six months of the request: (1) entities that were assigned 311 at the local level
prior to the effective date of this First Report and Order relinquish non-compliant uses;
and (2) it takes any steps necessary (for example reprogramming switch software) to
complete 311 calls from its subscribers to a requesting 311 entity in its service area.
85. IT IS FURTHER ORDERED, that (1) all providers of telephone exchange
service, both incumbents and new market entrants, whether facilities or non facilities-
based providers of telephone exchange service, should be enabled to use the 611 and
811 codes for repair services and business office uses as the incumbent LECs do now;
and (2) by dialing these N11 numbers, customers should be able to reach their own
carriers' repair or business services.
44
86. IT IS FURTHER ORDERED, that a LEC may not itself offer enhanced
services using a 411 code, or any other N11 code, unless that LEC offers access to the
code on a reasonable, nondiscriminatory basis to competing enhanced service
providers in the local service area for which it is using the code to facilitate distribution
of their enhanced services.
87. IT IS FURTHER ORDERED, that the North American Numbering Council
will explore how rapidly abbreviated dialing arrangements could be deployed and report
back to the Commission on this issue.
88. IT IS FURTHER ORDERED that GSA's request for a national N11
assignment is DENIED and that NASTD's request for a national assignment is
GRANTED IN PART as discussed in this First Report and Order, and otherwise
DENIED.
89. IT IS FURTHER ORDERED, pursuant to Sections 1, 4(i) and (j), 201-205,
218 and 251(e)(1) of the Communications Act as amended, 47 U.S.C. Sections 151,
154(i), 151(j), 201-205, 218 and 251(e)(1), that the Further Notice of Proposed
Rulemaking is hereby ADOPTED.
FEDERAL COMMUNICATIONS COMMISSION
William F. Caton
Acting Secretary
45
Appendix A
Comments Filed on N11 NPRM
CC Docket 92-105
Comments
1. Ad Hoc Telecommunications Users Committee (Ad Hoc)
2. Alternate Weekly Newspapers, New Times, Inc., Sasquatch
Publishing, City Pages, and Tuscon Weekly (Alternative Newspapers)
3. American Public Communications Council (APCC)
4. American Telephone and Telegraph Company (AT&T)
5. Ameritech Operating Companies (Ameritech)
6. Anchorage Telephone Utility (ATU)
7. Bell Atlantic Telephone Companies (Bell Atlantic)
8. Bell Communications Research, Inc. (Bellcore)
9. BellSouth Telecommunications, Inc. (BellSouth)
10. BT North America (BONA)
11. Canadian Steering Committee on Numbering (CSCN)
12. Central Telephone Company (Centel)
13. Cox Enterprises, Inc. (Cox)
14. Datatrex
15. Florida Public Service Commission (FPSC)
16. GTE Service Corporation (GTE)
17. Infocom International, Incorporated (Infocom)
18. Information Technology Association of America (ITAA)
19. Information Industry Association (IIA)
20. LO/AD Communications (LO/AD)
21. MCI Telecommunications Corporation (MCI)
22. Metropolitan Fiber Systems, Inc. (MFS)
23. Mobile Connections, Inc. (Mobile)
24. Mobile Telecommunications Technologies Corporation (Mtel)
25. National Telephone Cooperative Association (NTCA)
26. Newspaper Association of America (NAA)
27. NYNEX Telephone Companies (NYNEX)
28. Pacific Bell and Nevada Bell (Pacific)
29. Puerto Rico Telephone Company (PRTC)
30. Rochester Telephone Corporation (Rochester)
31. Southern New England Telephone (SNET)
32. Southwestern Bell Telephone Company (SWBT)
33. Sprint Corporation (Sprint)
34. Telesector Resources Group (Telesector)
35. United States Telephone Association (USTA)
36. U S WEST Communications, Inc. (U S WEST)
Reply Comments
46
1. Advance Publications, Inc. (Advance)
2. AT&T
3. Ameritech
4. Bell Atlantic
5. Bellcore
6. BellSouth
7. BONA
8. Cox
9. Datatrex
10. First Financial Management Corporation (FFMC)
11. FPSC
12. GTE
13. Illinois Commerce Commission, Indiana Utility Regulatory Commission,
Michigan Public Service Commission, Public Utilities Commission of Ohio, Public
Service Commission of Wisconsin (Ameritech Regional Regulatory Committee, or
ARRC)
14. Information Industry Association (IIA)
15. LO/AD
16. MCI
17. Mtel
18. National Center for Law and Deafness (NCLD)
19. New York State Department of Public Service (NYPDS)
20. Newsday
21. NYNEX
22. Organization for the Protection and Advancement
of Small Telephone Companies (OPASTCO)
23. Pacific
24. PBS/The Print Group
25. Sprint
26. SWBT
27. United Cerebral Palsy Association, Inc. (UCPA)
28. USTA
29. U S WEST
47
Appendix B
Comments Filed on TRS Petition
Comments
1. Access Independence and Mobility
2. Ad Hoc
3. ALDA California Style
4. ALDA Sacramento
5. Alexander Graham Bell Association for the Deaf, Inc.
American Council of the Blind
6. American Society for Deaf Children
7. American Speech-Language Hearing Association
8. Ameritech
9. Anderson, Herker
10. AT&T
11. Baltimore's Empowered Advocates for the
Right's of Deaf and Hard of Hearing People
12. Bell Atlantic
13. BellSouth
14. Bourne-Firl, Bridgetts
15. Center for Media Education
16. Chicago Hearing Society
17. Commonwealth of Massachusetts
18. Cox and Dallas Morning News
19. Deafness Education Advocacy Foundation
20. Eakes, Dorothy
21. Eakes, Malcolm
22. Fitts, Beth
23. Gallaudet University Regional Center- Ohlone College
24. Gallaudet University Regional Center- Kapiolani Community College
25. General Communications, Inc.
26. GTE
27. Hamilton Telephone Co.
28. Hawaii State Coordinating Council on Deafness
29. Helen Keller National Center
30. Illinois Commerce Commission, Indiana Utility Regulatory Commission,
Public Utilities Commission of Ohio, Public Service Commission of
Wisconsin
31. Illinois, Attorney General
32. Illinois Alliance for the Hearing Impaired
33. Jacksonville Community Center for the Deaf
34. Jacob, Philip
35. Joint Commission Indiana Utility Reg. Comm.,
Illinois Commerce Commission, PUC of Ohio and the PSC of Wisconsin
36. Jones, Samuel
48
37. Lake County Center for Independent Living
38. Leigh, Irene
39. Life After Deafness Magazine- Gayle McCullough
40. Life After Deafness
41. LING Inc.
42. Mame Telecommunications Relay Service Advisory Committee
43. McBroom, Betty
44. MCI
45. Minnesota Telecommunications Access for Communication-Impaired Persons
Board
46. Missouri Commission for the Deaf
47. National Technical Institute for the Deaf
48. National Association of the Deaf
49. New York Society for the Deaf
50. North Carolina; Division of Services for the Deaf and Hard of Hearing
51. North Country Club of the Deaf
52. Northern Virginia Resource Center for Deaf and Heard of Hearing Persons
53. NYNEX
54. Oregon Public Utility Commission
55. Oregon Association of the Deaf, Inc.
56. Pacific
57. People Mutual Telephone Company, Inc.
58. Public Utility Commission of Texas
59. Relay Texas Advisory Committee
60. Riker, David
61. Rochester Institute of Technology
62. Schaumberg Township Disabled Services
63. Self Help for Hard of Hearing People
64. South Carolina Telecommunications Relay Service Advisory Committee
65. South Carolina Budget and Control Board
66. SWBT
67. Springfield Center for Independent Living
68. Sprint Corporation for Sprint Communications Co. LP
& The 69. United and Centel Telephone Companies
70. Still, G. Howard
71. Telecommunications for the Deaf, Inc.
72. Telecommunications Relay Services Advisory Council
73. Texas Attorney General
74. Texas, Public Utility Commission
75. Triangle Association of the Deaf
76. USTA
77. United States Department of Agriculture
78. USDA- Southwestern Region
79. U S WEST Communications, Inc.
80. Virginia Department for the Deaf and Heard of Hearing (VDDHH)
81. Walker, Kristina Leitch
49
82. Washington Post Company
83. Wisconsin, Department of Health and Social Services
84. WisTRS
Reply Comments
1. Alexander Graham Bell Association for the Deaf
2. Association of Late Deafened Adults
3. Bell Atlantic
4. BellSouth
5. Chicago Hearing Society
6. Florida PSC
7. General Communication, Inc.
8. GTE
9. Illinois Alliance for the Hearing Impaired
10. Joint Parties (Cox and Dallas Morning Times)
11. Minnesota
12. National Association of the Deaf
13. National Center for Law and Deafness
14. National Fraternal Society of the Deaf
15. Nevada Bell
16. Newspaper Association of America
17. Pacific Bell
18. Pacific Telesis
19. Saks, Andrea
20. Self Help For Hard of Hearing People, Inc.
21. SWBT
22. Sprint Corporation, on Behalf of:
Sprint Communications Company LP
United & Central Telephone Companies
23. Telecommunications for the Deaf, Inc.
24. USTA
25. Washington Post
50
Appendix C
Comments Filed on GSA Petition
Comments
1. Acadian Ambulance Service, Inc.
2. Ad Hoc
3. American Public Telecommunications Council
4. Ameritech
5. Bell Atlantic
6. BellSouth
7. Caddo Parish Communications District No. One
8. Citizen Tribune
9. City of Dallas
10. Claiborne Parish Communications District
11. Consumer Product Safety Commission
12. Cox, Advance, Gannett, Washington Post
13. Daily Republic
14. Department of Agriculture
15. Department of Health and Human Services
16. The Department of Justice
17. Department of Transportation
18. Department of Veterans Affairs
19. Environmental Protection Agency
20. Federal Labor Relations Authority
21. Florida PSC
22. Goldsboro News-Argus
23. GTE
24. Idaho Public Utilities Commission
25. Information Industry Association
26. Iowa Utilities Board
27. Jackson Parish 9-1-1 Communication District
28. Louisiana Public Service Commission
29. MCI
30. Mulvany, Dana
31. National Aeronautics and Space Administration
32. National Association of Regulatory Utility Commissioners
33. National Association of State Telecommunications Directors
34. National Center for Law and Deafness, Nat'l Association of the Deaf,
Self Help for Hard of Hearing People, and
Telecommunications for the Deaf, Inc.
35. National Newspaper Association
36. Newspaper Association of America
37. Office of Personnel Management
38. Overseas Private Investment Corporation
39. Relay Administration Board
40. Southwestern Bell Corporation
51
41. Sprint
42. St. Charles Parish Communications District
43. St. Landry Parish Communications District
44. Stein, Paul
45. Tennessee Valley Authority
46. Texas Advisory Commission on State Emergency Communication
47. West Carroll Parish Communication District
48. Wilson Daily Times
Reply Comments
1. Acadian Ambulance Service, Inc.
2. Ad Hoc
3. American Public Telecommunications Council
4. Bell Atlantic
5. BellSouth
6. Caddo Parish Communications District No. One
7. Cox, Advance, Gannett, Washington Post Co.
8. Francis Dummer Fisher
9. General Services Administration
10. MCI
11. National Emergency Number Association (NENA)
12. National Newspaper Association
13. Southwestern Bell Corporation
14. Texas Department of Information
52
Appendix D
Comments Filed on Department of Justice Request
1. 311 Direct, Inc.
2. Ameritech
3. AT&T
4. Cincinnati Bell Telephone Company (CBT)
5. The County of Los Angeles
6. The Los Angeles Police Department
7. The Texas Department of Information resources (Texas DIR)
8. SBC Communications, Inc. (SBC)
9. U S WEST
10. Warren W. Owens
11. The Riverside County Sheriff's Department
12. The City of Austin
13. The Attorney General for the State of California
14. Dallas Police Department
15. Dallas Fire Chief
16. The Fort Worth Fire Chief
17. The Fire Chief of the City of Pittsburgh, Department of Public Safety
18. The Fire Chief of the Seattle Fire Department
19. The Commissioner of the Philadelphia Fire Department
20. The Fire Commissioner/Chief of the Boston Fire Department
21. The City of Garland Texas
22. Janice F. Hill
23. The City of Houston
24. The Maryland Chiefs of Police Association
25. The Maryland Public Service Commission (MDPSC)
26. The National Association of Police Organizations, Inc. (ANPO)
27. The National Sheriff's Association
28. The San Jose, California Police Department
29. The San Bernadino, California Police Department
30. The City of University Park, Texas
31. The National Fraternal Order of Police
32. The National Troopers Coalition
33. Daniel Ginty
34. The California Highway Patrol (CHP)
35. The City of Sacramento, California Police Department (Sacramento)
36. GTE
37. BellSouth
38. The Office of Information Resources of the Budget and Control Board of the
State of 39. South Carolina (South Carolina OIR)
40. Acadian Ambulance and AIR MED Services of Louisiana (Acadian)
41. The Ohio Department of Transportation (Ohio DOT)
42. The Commonwealth of Kentucky Transportation Cabinet (Kentucky DOT)
53
43. The Association of Public-Safety Communications Officials-International, Inc.
(APCO)
44. The Arizona APCO Chapter
45. Bismark Emergency Management & Combined Communications (Bismark)
46. Cox Enterprises, Inc.
47. The City of Fresno, California Chief of Police (Fresno Police Chief)
48. The Greater Harris County 9-1-1 Emergency Network
49. The City of Mesa, Arizona, Police Department Communications (Mesa)
50. Morris Communications Corporation (Morris)
51. The State of New York Department of Public Service (NYSDPS)
52. NYNEX
53. Florence Cainoce, Staff Manager for NYNEX Consumer Affairs
54. The Southern Idaho Regional Communications Center
55. The Texas Advisory Commission on State Emergency Communications (TX-
ACSEC)
56. The National Emergency Number Association (NENA) and the National
Association of State Nine One Administrators (NASNA) (National
911 Commenters)
57. Francis Dummer Fisher
58. Dr. Bill Munn, PhD, First Vice President of NENA
59. The Louisiana Public Service Commission
60. The National Association of the Deaf (NAD)
61. Bell Atlantic
62. Fairfax County Fire and Rescue Department, Fire Chief
63. County of Los Angeles Fire Department, Fire Chief
64. City of Miami Fire Chief
65. International Association of Fire Chiefs, Inc., and
International Municipal Signal Association 311
66. King County E-911 Program Manager (Seattle, Washington)
67. Cellular Telecommunications Industry Association
68. City of Phoenix Fire Department.
69. City and County of Denver Department of Safety, Chief of Police
70. Kootenai County, Idaho 911 Director
71. Charlotte-Mecklenburg, North Carolina Chief of Police
54
APPENDIX E: FINAL REGULATORY FLEXIBILITY ANALYSIS
1. As required by the Regulatory Flexibility Act (RFA), 5 U.S.C. § 601 et.
seq., the Commission considered regulatory flexibility issues in the Notice of Proposed
Rulemaking (NPRM) in this proceeding, and certified that there was no significant
economic impact on a substantial number of small entities.260 The Commission sought
written public comments on the proposals in the NPRM. Although there were no
comments filed in response to the certification, on our own motion we have
reconsidered our certification in the NPRM and decided to undertake a Final Regulatory
Flexibility Analysis (FRFA) in conformity with the RFA, as amended by the SBREFA.
A. Need for and Objectives of this First Report and Order
2. "Abbreviated dialing arrangements" are telephone numbers of less than
the standard 7 or 10 digits. Among abbreviated dialing arrangements, "N11 codes" are
3-digit telephone numbers of which the first digit may be any digit other than 0 or 1, and
the last two digits are both 1, e.g., 911. This First Report and Order directs Bell
Communications Research (Bellcore) to assign 711 as a national number for access to
telecommunications relay services for the deaf (TRS) and 311 as a national number for
access to non-emergency police services; concludes that, as the incumbent LECs can
do currently, all providers of telephone exchange service must be able to have their
customers call 611 and 811 to reach their repair and business service offices and that a
LEC may not itself offer enhanced services using a 411 code, or any other N11 code,
unless that LEC offers access to the code on a reasonable, nondiscriminatory basis to
competing enhanced service providers.
B. Analysis of Significant Issues Raised in Response to the
Certification
3. As stated above, no comments were submitted in response to the
Commission's certification in the NPRM that the rules it proposed to adopt in this
proceeding would not have a significant economic impact on a substantial number of
small business entities.261 Nonetheless, we have reconsidered our certification in the
NPRM and have decided to undertake an FRFA. We do so because the requirements
governing agency treatment of regulatory flexibility issues have become more stringent
while this docket has been open, and because even though a review of the general
comments for issues that might impact small businesses revealed that most comments
260 See NPRM at para. 21 We note that the certification was issued prior to enactment of the
amendments to the RFA in the Small Business Regulatory Enforcement Fairness Act of 1996
("SBREFA"), which was enacted as Title II of the Contract With America Advancement Act of 1996
(CWAAA), 5 U.S.C. § 605(b), Pub. L. No. 104-121, 110 Stat. 847 (1996).
261 See id.
55
did not specifically address possible impacts on small entities,262 we realize that a
substantial number of small entities may be affected by this First Report and Order. In
reaching our determinations in this First Report and Order, we have considered all
arguments raised by parties.
C. Description and Estimates of the Number of Small
Entities Affected by this First Report and Order
4. The RFA defines "small entity" to include the definition of "small business
concern" under the Small Business Act, 15 U.S.C. § 632.263 Under the Small Business
Act, a "small business concern" is one that: (1) is independently owned and operated;
(2) is not dominant in its field of operation; and (3) meets any additional criteria
established by the Small Business Administration (SBA).264 The SBA has defined
companies listed under Standard Industrial Classification (SIC) categories 4812
(radiotelephone communications) and 4813 (telephone communications, except
radiotelephone) to be small entities when they have 1500 or fewer employees. 265
These standards also apply in determining whether an entity is a small business for
purposes of the RFA.
5. Because the small incumbent LECs that would be subject to these rules
are either dominant in their field of operations or are not independently owned and
operated, consistent with our prior practice, they are excluded from the definition of
"small entity" and "small business concerns."266 Accordingly, our use of the terms
"small entities" and "small businesses" does not encompass small incumbent LECs. 267
262 We note that the Organization for the Promotion and Advancement of Small Telecommunications
Companies (OPASTCO) (formerly known as the Organization for the Protection and Advancement of
Small Telephone Companies), which represents more than 440 independently owned and operated
telephone companies serving rural areas, opposes mandatory assignment of N11 codes because they
could disrupt current use of an N11 code in some geographic areas (See OPASTCO Reply Comments
at 2-3, expressing concern about 611 and 811) and also argues that customer confusion could ensue if
services using N11 codes vary from area to area (See id. at 4).
263 See 5 U.S.C. § 601(6) (incorporating by reference the definition of "small business concern" in 15
U.S.C. § 632).
264 See 15 U.S.C. § 632(1)(a).
265 See 13 C.F.R. § 121.201, Standard Industrial Classification (SIC) Codes 4812 and 4813 (SIC 4812
and SIC 4813, respectively).
266 See Implementation of the Local Competition Provisions in the Telecommunications Act of 1996,
First Report and Order, 11 FCC Rcd 15499 (1996) (First Interconnection Order), motion for stay of the
FCC's rules pending judicial review denied, Implementation of the Local Competition Provisions in the
Telecommunications Act of 1996, Order, 11 FCC Rcd 11754 (1996), partial stay granted, Iowa Utilities
Board v. FCC, No. 96-3321, 1996 WL 589204 (8th Cir. Oct. 15, 1996) (Iowa Utilities Board v. FCC) at
paras. 1328-1330 and 1342.
267 See id. at para. 1342.
56
Out of an abundance of caution, however, for regulatory flexibility analysis purposes, we
will consider small incumbent LECs within this analysis and use the term "small
incumbent LECs" to refer to any incumbent LECs that arguably might be defined by
SBA as "small business concerns."
6. The decisions made by the Commission in this First Report and Order
may apply to a variety of entities listed below.
7. Local Exchange Carriers. Neither the Commission nor SBA has
developed a definition of small entity specifically applicable to providers of local
exchange services. The closest applicable definition is that under SBA rules for
telephone communications, except radiotelephone, SIC 4813, which defines a small
entity as one with 1500 or fewer employees. The most reliable source of information
regarding the number of LECs nationwide of which we are aware appears to be the data
that we collect annually in connection with the Telecommunications Relay Service
(TRS). According to our most recent data, 1,347 companies reported that they were
engaged in the provision of local exchange service. 268 Although it seems certain that
some of these carriers are not independently owned and operated, or have more than
1500 employees, we are unable at this time to estimate with any more certainty the
number of LECs that would qualify as small business concerns. Consequently, we
estimate that there are fewer than 1,347 small incumbent LECs that may be affected by
the decision and rules adopted in this First Report and Order.
8. Interexchange Carriers. Neither the Commission nor SBA has developed
a definition of small entity specifically applicable to providers of interexchange services
(IXCs). The closest applicable definition is that under SBA rules for telephone
communications, except radiotelephone, SIC 4813. The most reliable source of
information regarding the number of IXCs nationwide of which we are aware appears to
be the data that we collect annually in connection with TRS. According to our most
recent data, 130 companies reported that they were engaged in the provision of
interexchange services, and 30 companies reported they were engaged in "other" toll
services. 269 Although it seems certain that some of these carriers are not
independently owned and operated, or have more than 1500 employees, we are unable
at this time to estimate with greater precision the number of IXCs that would qualify as
small business concerns under SBA's definition. Consequently, we estimate that there
are fewer than 130 small entity IXCs and 30 "other" toll carriers that may be affected by
the decision and rules adopted in this First Report and Order.
268 Federal Communications Commission, CCB, Industry Analysis Division, Telecommunications Industry
Revenue: TRS Fund Worksheet Data, Tbl. 1 (Average Total Telecommunications Revenue Reported by
Class of Carrier) (Dec. 1996) (TRS Worksheet).
269 Id. Firms filing TRS Worksheets are asked to select a single category that best describes their
operation. As a result, some carriers describes themselves as IXCs, some as resellers, some as OSPs,
and some as "other."
57
9. Wireless Service Providers. Neither the Commission nor SBA has
developed a definition of small entity specifically applicable to providers of wireless
services. The closest applicable definition is that under SBA rules for radiotelephone
communications, SIC 4812, which defines a small entity as one with 1500 or fewer
employees. The 1992 Census of Transportation, Communications, and Utilities,
conducted by the Bureau of the Census, shows that only 12 radiotelephone firms out of
a total of 1,176 such firms that operated during 1992 had 1,000 or more employees. 270
Therefore, even if all 12 of these large firms were radiotelephone companies, all of the
remainder were small businesses under the SBA's definition. We assume that, for
purposes of our evaluations and conclusions in the FRFA, all of the current
radiotelephone licensees are small entities, as that term is defined by the SBA.
10. Cellular and Mobile Radio Telephone Service. In an effort to further
refine our calculation of the number of radiotelephone companies affected by the rules
adopted herein, we consider the categories of radiotelephone carriers, Cellular Service
Carriers and Mobile Service Carriers. Neither the Commission nor the SBA has
developed a definition of small entities specifically applicable to Cellular Service
Carriers and to Mobile Service Carriers. The closest applicable definition under SBA
rules for both services is for telephone companies other than radiotelephone (wireless)
companies. The most reliable source of information regarding the number of Cellular
Service Carriers and Mobile Service Carriers nationwide of which we are aware appears
to be the data that we collect annually in connection with the TRS. According to our
most recent data, 792 companies reported that they are engaged in the provision of
cellular services and 138 companies reported that they are engaged in the provision of
mobile services.271 Although it seems certain that some of these carriers are not
independently owned and operated, or have more than 1,500 employees, we are
unable at this time to estimate with greater precision the number of Cellular Service
Carriers and Mobile Service Carriers that would qualify as small business concerns
under SBA's definition. Consequently, we estimate that there are fewer than 792 small
entity Cellular Service Carriers and fewer than 138 small entity Mobile Service Carriers
that might be affected by the actions and rules adopted in this First Report and Order.
We assume that all of the current rural cellular and mobile licensees are small
businesses.
11. Personal Communications Service. The broadband PCS spectrum is
divided into six frequency blocks designated A through F and the Commission has held
auctions for each block. The Commission defined "small entity'' for Blocks C and F as
an entity that has average gross revenues of less than $40 million in the three previous
270 U.S. Bureau of the Census, U.S. Department of Commerce, 1992 Census of Transportation,
Communications, and Utilities, UC92-S-1, Subject Series, Establishment and Firm Size, Table 5,
Employment Size of Firms: 1992, SIC 4812 (issued May 1995).
271 See TRS Worksheet.
58
calendar years.272 For Block F, an additional classification for "very small business"
was added and is defined as an entity that, together with their affiliates, has average
gross revenues of not more than $15 million for the preceding three calendar years. 273
These regulations defining "small entity'' in the context of broadband PCS auctions have
been approved by the SBA. No small businesses within the SBA-approved definition
bid successfully for licenses in Blocks A and B. There were 90 winning bidders that
qualified as small entities in the Block C auctions. A total of 93 small and very small
business bidders won approximately 40% of the 1,479 licenses for Blocks D, E, and
F.274 However, licenses for blocks C through F have not been awarded fully, therefore
there are few, if any, small businesses currently providing PCS services. Based on this
information, we conclude that the number of small broadband PCS licensees will
include the 90 winning C Block bidders and the 93 qualifying bidders in the D, E, and F
blocks, for a total of 183 small PCS providers as defined by the SBA 275 and the
Commission's auction rules.
12. Paging and Radiotelephone Service, and Private Land Mobile Radio
Services, Paging Operations. Neither the Commission nor SBA has developed a
definition of small entity specifically applicable to providers paging services. The closest
applicable definition is that under SBA rules for radiotelephone communications, SIC
4812, which defines a small entity as one with 1500 or fewer employees. The
Commission anticipates that a total of 15,531 non-nationwide geographic area licenses
will be granted or auctioned. The geographic area licenses will consist of 3,050 MTA
licenses and 12,481 EA licenses. In addition to the 47 Rand McNally MTAs, the
Commission is licensing Alaska as a separate MTA and adding three MTAs for the U.S.
territories, for a total of 51 MTAs. No auctions of paging licenses have been held yet,
and there is no basis to determine the number of licenses that will be awarded to small
entities. Because nearly all radiotelephone companies have fewer than 1,000
employees, and no reliable estimate of the number of prospective paging licensees can
be made, we assume, for purposes of this FRFA, that all the 15,531 geographic area
paging licenses will be awarded to small entities, as that term is defined by the SBA.
We estimate that the approximately 600 current paging carriers could partition or
disaggregate a license or take the opportunity to obtain an additional license through
partitioning or disaggregation. We estimate that up to 48,393 licensees or potential
licensees could take the opportunity to partition or disaggregate a license or obtain a
license through partitioning or disaggregation. This estimate is based on the total
272 See Amendment of Parts 20 and 24 of the Commission's Rules -- Broadband PCS Competitive
Bidding and the Commercial Mobile Radio Service Spectrum Cap, Report and Order, FCC 96-278, WT
Docket No. 96-253, paras. 57- 60 (rel. June 24, 1996); See also 47 C.F.R. § 24.720(b) .
273 See Amendment of Parts 20 and 24 of the Commission's Rules -- Broadband PCS Competitive
Bidding and the Commercial Mobile Radio Service Spectrum Cap, Report and Order, FCC 96-278, WT
Docket No. 96-253, para. 60 (1996).
274 FCC News, Broadband PCS, D, E and F Block Auction Closes, Mimeo No. 71744 (rel. Jan. 14, 1997).
275 See para. 9, supra.
59
estimate of paging carriers (approximately 600) and non-nationwide geographic area
licenses to be awarded (15,531) and our estimate that each license will probably not be
partitioned or disaggregated among more than three parties. Because nearly all
radiotelephone companies have fewer than 1,000 employees, and no reliable estimate
of the number of future paging licensees can be made, we assume for purposes of this
FRFA that all of the licensees will be awarded to small businesses. We believe that it is
possible that a significant number of the estimated 48,393 licensees or potential
licensees who could take the opportunity to partition or disaggregate a license or who
could obtain a license through partitioning or disaggregation will be a small business.
13. Competitive Access Providers. Neither the Commission nor SBA has
developed a definition of small entity specifically applicable to providers of competitive
access services (CAPs). The closest applicable definition is that under SBA rules for
telephone communications, except radiotelephone, SIC 4813, which defines a small
entity as one with 1500 or fewer employees. The most reliable source of information
regarding the number of CAPs nationwide of which we are aware appears to be the
data that we collect annually in connection with TRS. According to our most recent data
57 companies reported that they were engaged in the provision of competitive access
services.276 Although it seems certain that some of these carriers are not independently
owned and operated, or have more than 1500 employees, we are unable at this time to
estimate with greater precision the number of CAPS that would qualify as small
business concerns under SBA's definition. Consequently, we estimate that there are
fewer than 57 small entity CAPS that may be affected by the decision and rules adopted
in this First Report and Order.
14. Operator Service Providers. Neither the Commission nor SBA has
developed a definition of small entity specifically applicable to providers of operator
services. The closest applicable definition is that under SBA rules for telephone
communications, except radiotelephone, SIC 4813. The most reliable source of
information regarding the number of operator service providers nationwide of which we
are aware appears to be the data that we collect annually in connection with TRS.
According to our most recent data 25 companies reported that they were engaged in the
provision of operator services.277 Although it seems certain that some of these carriers
are not independently owned and operated, or have more than 1500 employees, we are
unable at this time to estimate with greater precision the number of operator service
providers that would qualify as small business concerns under SBA's definition.
Consequently, we estimate that there are fewer than 25 small entity operator service
providers that may be affected by the decision and rules adopted in this First Report
and Order.
15. Pay Telephone Operators. Neither the Commission nor SBA has
developed a definition of small entity specifically applicable to providers of pay
276 See TRS Worksheet.
277 Id.
60
telephone operator services. The closest applicable definition is that under SBA rules
for telephone communications, except radiotelephone, SIC 4813. The most reliable
source of information regarding the number of pay telephone operators nationwide of
which we are aware appears to be the data that we collect annually in connection with
TRS. According to our most recent data, 271 companies reported that they were
engaged in the provision of pay telephone services. 278 Although it seems certain that
some of these carriers are not independently owned and operated, or have more than
1500 employees, we are unable at this time to estimate with greater precision the
number of pay telephone operators that would qualify as small business concerns under
SBA's definition. Consequently, we estimate that there are fewer than 271 pay
telephone operators that may be affected by the decision and rules adopted in this First
Report and Order.
16. Resellers. Neither the Commission nor the SBA has developed a
definition of small entity specifically applicable to resellers. The closest applicable
definition is that under SBA rules for all telephone communications companies, SIC
4812 and SIC 4813, combined, both of which define a small entity as one with 1500 or
fewer employees. The most reliable source of information regarding the number of
resellers nationwide of which we are aware appears to be the data that we collect
annually in connection with TRS. According to our most recent data, 260 companies
reported that they were engaged in the resale of telephone services.279 Although it
seems certain that some of these carriers are not independently owned and operated,
or have more than 1500 employees, we are unable at this time to estimate with greater
precision the number of resellers that would qualify as small business concerns under
SBA's definition. Consequently, we estimate that there are fewer than 260 small entity
resellers that may be affected by the decision and rules adopted in this First Report and
Order.
17. Telecommunications Equipment Manufacturers. The SBA classifies
manufacturers of telecommunications equipment in two categories, one for wireless and
another for wireline.
18. Wireline Telecommunications Equipment Manufacturers. Neither the
Commission nor the SBA has developed a specific definition of small entities applicable
to manufacturers of wireline telecommunications equipment. Therefore, we will utilize
the SBA definition of manufacturers of Telephone and Telegraph Apparatus. According
to the SBA's regulations, a small entity must have 1000 or fewer employees in order to
qualify as a small business concern.280 Census Bureau data indicates that there are
479 U.S. firms that manufacture telephone and telegraph equipment, and that 436 of
these firms have fewer than 1000 employees and would be classified as small
278 Id.
279 Id.
280 13 C.F.R. § 121.201, SIC 3661.
61
entities.281 The Census Bureau category is very broad, and specific figures are not
available as to how many of these firms are manufacturers of wireline
telecommunications equipment that would be subject to these rules or how many are
independently owned and operated. Consequently, we estimate that there are fewer
than 436 small manufacturers of wireline telecommunications equipment.
19. Wireless Telecommunications Equipment Manufacturers. Neither the
Commission nor the SBA has developed a specific definition of small entities applicable
to manufacturers of wireless telecommunications equipment. Therefore, we will utilize
the SBA definition of manufacturers of Radio and Television Broadcasting and
Communications Equipment.282 According to the SBA's regulations, a small entity must
have 750 or fewer employees in order to qualify as a small business concern. 283
Census Bureau data indicates that there are 858 U.S. firms that manufacture radio and
television broadcasting and communications equipment, and that 778 of these firms
have fewer than 750 employees and would be classified as small entities. 284 The
Census Bureau category is very broad, and specific figures are not available as to how
many of these firms are manufacturers of wireless telecommunications equipment or
how many are independently owned and operated. Consequently, we estimate that
there are fewer than 778 small manufacturers of wireless telecommunications
equipment.
20. Fire and Burglar Equipment Manufacturers. The Commission has not
developed a definition of small entities applicable to manufacturers of fire and burglar
alarm equipment. We will utilize the SBA classification of such manufacturers under
Communications Equipment Not Elsewhere Classified. This definition provides that a
small entity is an alarm equipment manufacturer employing 750 or less persons. 285
Census Bureau data indicates that there are 498 U.S. firms that manufacture alarm
equipment, and that 469 of these firms have fewer than 750 employees and would be
classified as small entities.286 The Census Bureau category is very broad, and includes
manufacturers of other equipment such as traffic signalling and intercommunications
equipment. Specific figures are not available as to how many of these firms produce
281 U.S. Dept. of Commerce, 1992 Census of Transportation, Communications and Utilities, Table 1D,
(issued May 1995), SIC 3661.
282 This category excludes establishments primarily engaged in the manufacturing of household audio
and visual equipment which is categorized as SIC 3651.
283 13 C.F.R. § 121.201, SIC 3663.
284 U.S. Dept. of Commerce, 1992 Census of Transportation, Communications and Utilities, Table 1D,
(issued May 1995), SIC 3663.
285 13 C.F.R. § 121.201, SIC 3669.
286 U.S. Dept. of Commerce, 1992 Census of Transportation, Communications and Utilities, Table 1D,
(issued May 1995), SIC 3669.
62
alarm equipment or how many are independently owned and operated. Consequently,
we estimate that there are fewer than 469 small manufacturers of alarm equipment that
may be affected by the decision and rules adopted in this First Report and Order.
21. Alarm Service Providers. The SBA has developed a definition of alarm
service providers (SIC 7382) which are entities that are primarily engaged in the
monitoring and maintenance of security systems devices, such as burglar and fire
alarms.287 According to the SBA, a small security system provider must have $9 million
or less in annual receipts.288 Census Bureau data reports that there were 2,190 security
system service providers with $7.499 million or less in annual receipts and 2,200 with
less than $9.999 million in annual receipts.289 Therefore, we tentatively conclude that
there are approximately 2,190 small security system service providers that may be
affected by the decision and rules adopted in this First Report and Order.
D. Description of Projected Reporting, Recordkeeping
and Other Compliance Requirements of the Rules
22. The First Report and Order requires Bell Communications Research, as
the NANP administrator, to assign, as of the effective date of this First Report and
Order, to assign 311 as a national code for access to non-emergency police and other
government services and to assign 711 as a national code for TRS use. The First
Report and Order also requires that when a provider of telecommunications services
receives a request from an entity (for example a local police chief or local fire chief) to
use 311 for access to non-emergency police and other government services in a
particular jurisdiction, it must ensure that, within six months of the request: (1) entities
that were assigned 311 at the local level prior to the effective date of this First Report
and Order relinquish non-compliant uses; and (2) it takes any steps necessary (for
example reprogramming switch software) to complete 311 calls from its subscribers to a
requesting 311 entity in its service area. We recognize that some of these requirements
may require the use of professional engineering skills.
E. Significant Alternatives Minimizing Impact on Small
Entities and Consistent with Stated Objectives
23. The Commission considers and implements alternatives in this First
Report and Order that seek to benefit competing providers of telephone exchange
service and telephone toll service which may include small business entities. As
287Standard Industrial Classification Manual, (SIC) 7382, Executive Office of the President, Office of
Management and Budget (1987).
288 13 C.F.R. § 121.201, SIC 7382.
289 1992 Economic Census Industry and Enterprise Receipts Size Report, Table 2D, SIC 7382 (U.S.
Bureau of the Census data under contract to the Office of Advocacy of the U.S. Small Business
Administration).
63
alternatives to the determination to require Bellcore to assign 311 as a national number
for access to non-emergency police services and 711 for national TRS access, we
considered, for example, the possibility of using other numbering resources such as 800
numbers. See First Report and Order at paras. 40 and 55. The Commission's
determination to allow local governments to determine whether they need to avail
themselves of the 311 non-emergency option should serve to lessen possible
implementation burdens (cost, time, etc.) on smaller telecommunications carriers in
particular. This determination avoids not only unnecessary investments for providers
of telecommunications services but also unnecessary relinquishment of the customers'
(some of which may be small) uses of 311 assignments made at the local level prior to
the effective date of the First Report and Order. Furthermore, allowing six months from
a request for 311 service in a local jurisdiction to prepare for 311 non-emergency
service should lessen implementation burdens that may have been more costly if
implementation were required during a shorter period. This six-month period should
prove beneficial also to customers that were assigned 311 at the local level prior to the
effective date of the First Report and Order. See First Report and Order at paras. 35-
43.
F. Report to Congress
24. The Commission shall send a copy of this Final Regulatory Flexibility
Analysis, along with this First Report and Order, in a report to Congress pursuant to the
Small Business Regulatory Enforcement Fairness Act of 1996, 5 U.S.C. § 801(a)(1)(A).
A copy of this FRFA will also be published in the Federal Register.
64
APPENDIX F: INITIAL REGULATORY FLEXIBILITY ANALYSIS
65
1. As required by the Regulatory Flexibility Act (RFA), 5 U.S.C. § 601 et seq.,
the Commission is incorporating an Initial Regulatory Flexibility Analysis (IRFA) of the
expected impact on small entities of the policies and proposals in this Further Notice of
Proposed Rulemaking (FNPRM).290 Written public comments concerning the effect of
the proposals in the FNPRM, including the IRFA, on small businesses are requested.
Comments must be identified as responses to the IRFA and must be filed by the
deadlines for the submission of comments in this proceeding. The Secretary shall send
a copy of this FNPRM, including the IRFA, to the Chief Counsel for Advocacy of the
Small Business Administration in accordance with paragraph 603(a) of the RFA,
amended by the SBREFA.
A. Reasons Why the Actions Are Being Considered and
Need for and Objectives of this FNPRM
2. The FNPRM is initiated to obtain comment on the technical feasibility of
implementing 711 for TRS access. The FNPRM also asks parties: (1) if it would be
possible to develop within a reasonable time an N11 "gateway" offering access to
multiple TRS providers; (2) whether, with such gateway access, TRS calls would still be
answered within our mandatory minimum standards for TRS answer times; (3) whether
such a gateway would be consistent with Section 255 of the Telecommunications Act of
1934 (Act), as amended by the Telecommunications Act of 1996;291 and (4) whether
any other important disability services could be accessed through the same gateway.
Regarding TRS, the FNPRM also requests comment from interested parties, particularly
TRS providers, about the possibility of providing both voice and text TRS services
through the same abbreviated N11 code. Finally, the FNPRM asks for comment on the
proprietary nature of N11 codes and on our proposal to transfer the administration of
N11 codes at the local level from the incumbent LECs to the NANP administrator. The
objective of this FNPRM is to develop a record that addresses issues related to the
efficient use of scarce numbering resources and adheres to the imperative, concomitant
with the need for one uniform numbering plan, that any numbering plan be capable of
serving all telecommunications carriers, both incumbents and new market entrants.
B. Legal Basis
3. Authority for actions proposed in this FNPRM may be found in: Sections 1,
4(i) and (j), 201-205, 218 and 251(e)(1) of the Communications Act as amended, 47
U.S.C. Sections 151, 154(i), 151(j), 201-205, 218 and 251(e)(1).
C. Reporting, Recordkeeping and Other Compliance Requirements
290Pub. L. No. 96-354, 94 Stat. 1164, 5 U.S.C. § 601 et. seq. (1981), as amended. Amendments to the
RFA were enacted in the Small Business Regulatory Enforcement Fairness Act of 1996 ("SBREFA"),
which was enacted as Title II of the Contract With America Advancement Act of 1996 (CWAAA), Pub. L.
No. 104-121, 110 Stat. 847 (1996).
291 Telecommunications Act of 1996, Pub. L. No. 104-104, 110 Stat. 56 (1996).
4. No new recording, recordkeeping or other compliance requirements are
proposed.
D. Federal Rules that Duplicate, Overlap, or Conflict With Proposed
Rules
5. None.
E. Description and Estimate of the Number of Small
Entities To Which the Proposed Rules Would Apply
6. For entities to which the proposals in this FNPRM may apply, as well as
for the definition of small entity and discussion of small independent LECs, See
Appendix E, supra, Final Regulatory Flexibility Analysis, Heading C (Description and
Estimates of the Number of Small Entities Affected by this First Report and Order)
(paras. 4-21). In addition, as described below, the proposed rules would apply to TRS
providers.
7. TRS Providers. Neither the Commission nor SBA has developed a
definition of small entity specifically applicable to providers of telecommunications relay
services (TRS). The closest applicable definition is that under SBA rules for telephone
communications, except radiotelephone, SIC 4813. According to our most recent data,
there are 12 interstate TRS providers, which consist of interexchange carriers, 292 local
exchange carriers,293 state entities, and non-profit organizations. Although it seems
certain that some of these TRS providers are not independently owned and operated, or
have more than 1500 employees, we are unable at this time to estimate with greater
precision the number of TRS providers that would qualify as small business concerns
under SBA's definition. Consequently, we estimate that there are fewer than 12 small
entity TRS providers that may be affected by the proposals in this FNPRM.
F. Significant Alternatives Minimizing Impact on Small
Entities and Consistent with Stated Objectives
8. The proposals in the FNPRM, and the comments the Commission seeks
regarding them, are part of the Commission's analysis of its role with respect to
numbering administration. The guiding principal shaping these proposals is that a
uniform numbering plan is an essential prerequisite to an integrated public switched
telephone network. There must be a single, consistent set of numbering principles
allowing all switching equipment connected to the network to route every call to its
correct destination. Concomitant with the need for one uniform numbering plan is the
imperative that any numbering plan be capable not only of serving incumbents, but also
of accommodating new market entrants. For this reason, we have attempted, wherever
possible, to ensure that new telecommunications carriers have access to numbering
resources on the same basis as incumbents. These competing providers of telephone
292 See Appendix E, supra, Final Regulatory Flexibility Analysis at para. 8.
293 See id. at para. 7.
2
exchange service and telephone toll service may include small business entities. To
gather information from all interested parties about alternative timeframes for nationwide
implementation of 711 for TRS access, in addition to seeking comment on our tentative
conclusion that this implementation should occur within three years of the effective date
of the First Report and Order, we ask, among other things, that parties addressing
implementation issues present a timeline for completion of steps they foresee as
necessary to introduce 711. See First Report and Order at para. 68. We tentatively
conclude that our proposals in the FNPRM would impose minimum burdens on small
entities. We seek comment on this tentative conclusion.
3
ATTACHMENT 3
311 INITIAL
SURVEY
DATE POPULATION INITIAL ANNUAL ANNUAL MANAGED "211" TYPE SVC.
CITY STATE STARTED SERVED COSTS COSTS STAFF CALLS BY Y/N CITY/NON-EMER
Detroit MI 1997 1,000,000 $2,000 NA 61 780,000 Police Dept. Y City Service Calls
San Jose CA 1997 1,300,000 $175,000 $100,000 6 262,870 Police Dept. N Non-Emergency
Baltimore MD 1997 670,000 $60,000 $20,000 8 600,000 Police Dept. N Non-Emergency
Las Vegas NV 2000 2,000,000 * NA 17 1,000,000 Police Dept. N Non-Emergency
Chicago IL 1998 3,000,000 $3,997,949 $788,141 12 10,000,000Police Dept. N City Service Calls
Columbia SC 2002 117,000 $300,000 $400,000 5 26,000 311 Call Ctr. Y City Service Calls
Hampton VA 1999 146,000 $300,000 $427,000 9 237,000 DPW. N City Service Calls
Rochester NY 1998 200,000 $999,672 $443,992 12 750,000 Police Dept. N Non-Emergency
Austin TX 2001 552,434 $350,000 $6,600 27 2,700,000 Police Dept. N Non-Emergency
Houston TX 2001 1,500,000 $2,333 $5,399 77 16,000,000Mayor's N City Service Calls
Office
Washington D.C. 2000 1,500,000 $5,900,000 $1,300 173 1,000,000 Police Dept. N Non-Emergency
San Antonio TX 2002 1,400,000 29 600,000 Customer N City Service Calls
Services
ATTACHMENT 4
PSAP NAME Wireless Wireline Wireless Wireline Wireless Wireline Wireless Wireline Wireless Wireline Wireless Wireline Wireless Wireline
Call Volume 2002 Jan Jan Feb Feb March March April April May May June June July July
Ansonia PD 84 442 64 376 78 398 67 396 81 398 98 445 80 4
Avon PD 87 205 58 234 43 354 16 445 20 488 16 588 7 5
Berlin PD 85 317 90 279 97 340 74 408 89 448 69 442 81 4
Bethel PD 62 283 32 267 45 347 39 330 37 353 40 374 25 3
Bloomfield PD 118 675 91 639 75 807 60 912 72 1,067 75 1,117 53 10
Branford PD 108 648 140 586 163 647 139 700 148 865 181 835 187 9
Bridgeport FD 252 8,106 260 7,244 245 8,060 325 8,540 354 9,331 368 10,175 393 107
Bristol PD 173 1,224 129 1,077 61 1,654 23 2,060 34 2,157 5 2,395 7 31
Brookfield PD 84 261 64 235 69 312 42 511 59 656 90 663 83 23
Canton PD 23 96 33 94 8 208 6 190 2 192 7 235 2 2
Cheshire PD 90 466 77 376 93 485 43 614 60 701 50 727 49 7
Clinton ECC 37 196 23 168 43 166 33 186 50 200 59 193 72 2
Colchester EC 860 707 820 557 938 622 948 597 1,213 717 1,137 701 1141 7
Cromwell PD 73 237 68 214 59 302 78 277 75 246 106 286 89 2
Danbury FD 512 1,938 386 1,673 503 1,977 455 2,152 512 2,358 548 2,270 546 25
Darien PD 71 406 66 400 84 414 85 456 112 451 109 524 70 4
Deep River ECC 7 226 6 171 6 173 11 199 12 247 10 212 16 2
Derby PD 87 281 92 293 131 312 95 267 108 389 127 354 112 3
East Hartford PD 188 1,282 174 1,261 206 1,516 214 1,497 218 1,600 249 1,688 284 18
East Haven FD 140 682 120 639 132 710 114 847 128 743 146 803 152 8
East Lyme ECC 12 1,547 9 1,404 6 1,699 8 1,789 18 2,024 11 2,242 17 22
East Windsor PD 55 231 49 214 35 269 58 321 59 356 44 369 64 3
Easton PD 30 116 19 97 20 112 16 116 23 120 17 117 18 1
Enfield PD 128 678 135 600 117 783 148 881 125 837 190 920 177 9
Fairfield ECC 239 1,206 218 1,196 223 1,259 227 1,302 317 1,432 307 1,348 297 12
Farmington PD 141 401 120 357 76 527 42 798 46 896 54 844 57 10
Glastonbury PD 78 371 59 335 76 471 70 562 95 536 98 505 112 5
Granby PD 41 196 26 178 14 542 3 349 9 475 4 449 5 4
Greenwich PD 272 1,710 192 1,511 274 1,692 241 1,890 354 1,880 343 2,211 312 20
Groton ECC 176 1,010 160 856 174 1,074 191 1,133 212 1,220 195 1,337 209 13
Guilford ECC 37 435 22 352 36 399 18 382 37 419 32 438 30 4
Hamden ECC 306 1,427 272 1,205 296 1,341 268 1,556 272 1,657 274 1,586 265 17
Hartford PD 1,805 9,137 1,676 8,779 1,710 10,549 1,944 11,019 2,106 13,190 1,940 12,382 2098 129
Ledyard ECC 6 257 1 216 4 1,357 4 1,212 3 436 1 518 1 5
Litchfield LCD 2,163 842 1,909 733 1,720 781 1,335 883 1,662 870 1,347 944 1418 11
Madison PD 49 271 38 247 46 277 37 245 65 280 80 307 110 3
Manchester PD 306 1,210 274 1,080 289 1,278 296 1,347 357 1,380 370 1,489 362 15
Meriden PD 277 1,352 252 1,200 285 1,428 283 1,578 323 1,683 392 1,837 369 18
Middlebury PD 22 110 37 108 30 118 34 154 42 158 39 193 47 1
Middletown FD 502 6,284 392 4,695 290 1,356 328 1,421 397 1,455 427 1,389 385 14
Milford FD 263 1,116 248 992 225 1,136 258 1,144 311 1,281 291 1,301 320 13
Monroe PD 81 277 58 230 74 340 27 482 29 520 36 583 18 6
Montville ECC 6 1,105 11 967 8 1,096 3 1,196 5 1,407 11 1,227 8 13
Naugatuck PD 117 559 71 473 99 528 111 530 115 555 120 568 113 6
New Britain ERC 402 2,501 349 2,283 357 2,677 350 2,849 378 3,145 359 3,214 388 32
New Canaan PD 80 346 61 295 50 305 45 334 56 348 47 364 59 4
New Fairfield PD 10 149 6 154 6 211 2 193 8 220 3 224 4 2
New Haven ECC 1,300 6,269 1,218 5,552 1,359 6,626 1,429 7,168 1,551 7,820 1,632 7,970 1647 87
New London PD 195 1,104 207 972 220 2,495 250 3,537 192 3,643 216 3,638 259 40
New Milford PD 97 350 60 320 53 437 34 497 53 559 67 624 46 5
Newington PD 185 678 169 637 130 725 90 1,053 103 1,178 111 1,056 108 11
Newtown PD 121 405 86 337 108 415 83 406 102 514 120 439 94 5
North Branford PD 50 181 50 138 41 199 45 209 47 236 38 291 48 2
North Haven PD 155 507 148 443 159 458 137 493 161 496 141 575 175 6
Northwest CT PS 4,084 627 3,701 508 4,291 599 4,342 617 4,498 666 5,218 709 5094 7
Norwalk PD 522 2,548 438 2,299 538 2,383 518 2,525 663 2,656 680 2,640 605 28
Norwich PD 251 1,072 158 1,040 237 1,042 200 1,251 224 1,332 253 1,296 235 15
Old Saybrook PD 43 230 33 160 30 203 38 196 54 188 64 218 73 2
Orange PD 137 270 122 209 156 309 108 325 159 342 145 369 148 3
Plainville PD 74 422 66 366 50 492 51 483 41 603 46 612 57 5
Plymouth EC 33 176 25 200 10 283 8 278 6 270 7 397 9 3
Putnam PD 20 190 10 198 22 166 16 230 18 220 23 257 15 2
Quinebaug ECC 1,041 1,586 925 1,293 1,031 1,469 1,072 1,409 1,363 1,505 1,291 1,648 1349 17
Redding PD 49 98 33 98 24 145 7 175 8 192 7 187 12 2
Ridgefield PD 119 490 88 408 81 547 36 643 40 691 42 713 44 7
Rocky Hill PD 66 333 51 314 45 376 55 460 75 467 78 513 68 5
Seymour PD 25 246 18 215 37 235 22 238 24 264 45 258 25 2
Shelton PD 167 806 106 667 161 722 123 800 172 855 147 931 149 9
Simsbury PD 95 307 66 280 35 353 9 366 14 405 8 464 9 5
South Windsor 52 340 60 309 41 346 40 404 53 485 36 436 48 4
Southbury PD 36 331 36 284 25 321 38 280 42 339 36 350 53 3
South Cent Reg ECC 21 508 13 392 26 444 20 484 25 501 27 497 23 5
Southington PD 143 689 122 622 134 729 123 762 155 880 135 823 145 8
Stamford PD 833 4,713 667 4,383 769 4,735 826 4,634 942 4,999 1,093 5,118 1024 49
State Police Trp "A" 5,154 128 4,452 134 5,013 152 4,710 220 5,486 263 5,626 274 5481 2
State Police Trp "B" 248 176 209 117 259 144 222 136 222 145 269 164 314 2
State Police Trp "C" 441 257 341 241 456 306 477 293 417 318 498 403 507 3
State Police Trp "D" 227 280 169 240 221 277 204 320 260 290 273 337 286 3
State Police Trp "E" 5,387 449 4,596 369 5,066 438 4,567 549 5,210 616 5,331 653 5871 8
State Police Trp "F" 367 135 289 95 381 130 348 121 375 109 526 148 551 1
State Police Trp "G" 27,147 204 23,595 167 27,937 247 29,096 357 32,266 402 34,090 550 32145 8
State police Trp "H" 22,358 197 20,041 230 20,917 499 20,143 684 20,984 733 21,062 569 21830 5
2
State Police Trp "I" 8,665 129 8,075 142 8,330 211 8,024 341 9,272 413 9,019 414 8981 5
State Police Trp "W" 8 526 5 540 0 504 3 479 1 472 2 491 3 5
Stonington PD 48 313 42 273 46 348 45 430 55 547 63 589 74 6
Stratford PD 256 1,238 219 1,144 227 1,242 262 1,386 297 1,579 315 1,526 318 15
Suffield PD 3 169 156 0 210 1 217 0 198 2 223 0 2
Thomaston PD 19 93 9 70 16 96 4 112 17 92 18 115 11
Tolland County MAD 2,090 1,188 1,827 1,160 2,159 1,318 2,184 1,434 2,412 1,593 2,462 1,431 2430 15
Torrington PD 124 788 87 679 141 720 115 708 151 782 145 852 175 8
Trumbull PD 144 726 84 661 131 636 91 758 97 949 94 836 95 8
Valley Shore EC 3,898 677 3,448 542 3,765 599 4,001 620 5,158 754 5,742 793 6062 9
Vernon PD 111 509 115 438 115 546 151 554 170 550 160 593 178 6
Wallingford FD 234 640 166 605 148 747 143 862 160 956 182 985 180 9
Waterbury PD 1,061 4,316 840 3,799 989 3,972 1,086 3,998 1,218 4,352 1,464 4,788 1356 51
Waterford ECC 92 407 91 367 88 489 70 609 74 677 105 692 97 7
Watertown PD 57 308 80 304 65 315 53 422 62 403 46 398 61 4
West Hartford PD 329 1,269 292 991 196 1,345 196 1,646 194 1,683 229 1,747 239 19
West Haven ERS 244 1,852 248 1,712 284 1,909 323 1,999 362 2,211 390 2,361 331 22
Weston ECC 40 236 25 169 28 162 21 253 28 273 30 286 16 2
Westport PD 126 632 124 556 147 642 160 589 237 712 232 724 218 6
Wethersfield PD 100 539 108 456 86 593 69 693 101 687 100 694 103 7
Willimantic FD 21 1,667 11 1,503 26 1,591 22 1,616 18 1,801 31 1,694 37 18
Wilton PD 118 329 112 264 82 351 50 456 50 509 59 553 41 5
Windsor Locks PD 34 249 23 205 20 256 14 253 29 314 38 310 22 3
Windsor PD 92 492 722 87 542 81 654 100 688 111 705 107 7
Winsted PD 26 183 41 177 27 203 36 191 47 221 32 222 53 2
Wolcott PD 37 214 36 182 41 187 27 204 43 181 37 171 46 2
Woodbridge PD 42 148 42 116 50 178 48 161 47 180 47 153 47 1
100,007 100,661 87,975 89,710 96,976 102,768 95,981 111,498 107,213 121,346 111,058 124,406 110,540 133,4
PSAP NAME Wireless Wireless Wireless Wireless Wireless Wireless 6 month
Call Volume 2002 Jan Feb Mar April May June TOTAL
Ansonia PD 84 64 78 67 81 98 472
3
Avon PD 87 58 43 16 20 16 240
Berlin PD 85 90 97 74 89 69 504
Bethel PD 62 32 45 39 37 40 255
Bloomfield PD 118 91 75 60 72 75 491
Branford PD 108 140 163 139 148 181 879
Bridgeport FD 252 260 245 325 354 368 1,804
Bridgeport PD 1,313 1,127 1,494 1,462 1,722 1,770 8,888
Bristol PD 173 129 61 23 34 5 425
Brookfield PD 84 64 69 42 59 90 408
Canton PD 23 33 8 6 2 7 79
Cheshire PD 90 77 93 43 60 50 413
Clinton ECC 37 23 43 33 50 59 245
Colchester EC 860 820 938 948 1,213 1,137 5,916
Cromwell PD 73 68 59 78 75 106 459
Danbury FD 512 386 503 455 512 548 2,916
Danbury PD 304 226 249 226 238 265 1,508
Darien PD 71 66 84 85 112 109 527
Deep River ECC 7 6 6 11 12 10 52
Derby PD 87 92 131 95 108 127 640
East Hartford PD 188 174 206 214 218 249 1,249
East Haven FD 140 120 132 114 128 146 780
East Lyme ECC 12 9 6 8 18 11 64
East Windsor PD 55 49 35 58 59 44 300
Easton PD 30 19 20 16 23 17 125
Enfield PD 128 135 117 148 125 190 843
Fairfield ECC 239 218 223 227 317 307 1,531
Farmington PD 141 120 76 42 46 54 479
Glastonbury PD 78 59 76 70 95 98 476
Granby PD 41 26 14 3 9 4 97
Greenwich PD 272 192 274 241 354 343 1,676
Groton ECC 176 160 174 191 212 195 1,108
Guilford ECC 37 22 36 18 37 32 182
Hamden ECC 306 272 296 268 272 274 1,688
4
Hartford PD 1,805 1,676 1,710 1,944 2,106 1,940 11,181
Ledyard ECC 6 1 4 4 3 1 19
Litchfield LCD 2,163 1,909 1,720 1,335 1,662 1,347 10,136
Madison PD 49 38 46 37 65 80 315
Manchester PD 306 274 289 296 357 370 1,892
Meriden PD 277 252 285 283 323 392 1,812
Middlebury PD 22 37 30 34 42 39 204
Middletown FD 502 392 290 328 397 427 2,336
Milford FD 263 248 225 258 311 291 1,596
Monroe PD 81 58 74 27 29 36 305
Montville ECC 6 11 8 3 5 11 44
Naugatuck PD 117 71 99 111 115 120 633
New Britain ERC 402 349 357 350 378 359 2,195
New Canaan PD 80 61 50 45 56 47 339
New Fairfield PD 10 6 6 2 8 3 35
New Haven ECC 1,300 1,218 1,359 1,429 1,551 1,632 8,489
New London PD 195 207 220 250 192 216 1,280
New Milford PD 97 60 53 34 53 67 364
Newington PD 185 169 130 90 103 111 788
Newtown PD 121 86 108 83 102 120 620
North Branford PD 50 50 41 45 47 38 271
North Haven PD 155 148 159 137 161 141 901
Northwest CT PS 4,084 3,701 4,291 4,342 4,498 5,218 26,134
Norwalk PD 522 438 538 518 663 680 3,359
Norwich PD 251 158 237 200 224 253 1,323
Old Saybrook PD 43 33 30 38 54 64 262
Orange PD 137 122 156 108 159 145 827
Plainville PD 74 66 50 51 41 46 328
Plymouth EC 33 25 10 8 6 7 89
Putnam PD 20 10 22 16 18 23 109
Quinebaug ECC 1,041 925 1,031 1,072 1,363 1,291 6,723
Redding PD 49 33 24 7 8 7 128
Ridgefield PD 119 88 81 36 40 42 406
5
Rocky Hill PD 66 51 45 55 75 78 370
Seymour PD 25 18 37 22 24 45 171
Shelton PD 167 106 161 123 172 147 876
Simsbury PD 95 66 35 9 14 8 227
South Windsor 52 60 41 40 53 36 282
Southbury PD 36 36 25 38 42 36 213
South Cent Reg ECC 21 13 26 20 25 27 132
Southington PD 143 122 134 123 155 135 812
Stamford PD 833 667 769 826 942 1,093 5,130
State Police Trp "A" 5,154 4,452 5,013 4,710 5,486 5,626 30,441
State Police Trp "B" 248 209 259 222 222 269 1,429
State Police Trp "C" 441 341 456 477 417 498 2,630
State Police Trp "D" 227 169 221 204 260 273 1,354
State Police Trp "E" 5,387 4,596 5,066 4,567 5,210 5,331 30,157
State Police Trp "F" 367 289 381 348 375 526 2,286
State Police Trp "G" 27,147 23,595 27,937 29,096 32,266 34,090 174,131
State police Trp "H" 22,358 20,041 20,917 20,143 20,984 21,062 125,505
State Police Trp "I" 8,665 8,075 8,330 8,024 9,272 9,019 51,385
State Police Trp "K" 295 253 294 257 323 385 1,807
State Police Trp "L" 244 258 313 266 341 304 1,726
State Police Trp "W" 8 5 0 3 1 2 19
Stonington PD 48 42 46 45 55 63 299
Stratford PD 256 219 227 262 297 315 1,576
Suffield PD 3 0 1 0 2 6
Thomaston PD 19 9 16 4 17 18 83
Tolland County MAD 2,090 1,827 2,159 2,184 2,412 2,462 13,134
Torrington PD 124 87 141 115 151 145 763
Trumbull PD 144 84 131 91 97 94 641
UCONN PD 5 17 19 29 12 11 93
Valley Shore EC 3,898 3,448 3,765 4,001 5,158 5,742 26,012
Vernon PD 111 115 115 151 170 160 822
Wallingford FD 234 166 148 143 160 182 1,033
Waterbury PD 1,061 840 989 1,086 1,218 1,464 6,658
6
Waterford ECC 92 91 88 70 74 105 520
Watertown PD 57 80 65 53 62 46 363
West Hartford PD 329 292 196 196 194 229 1,436
West Haven ERS 244 248 284 323 362 390 1,851
Weston ECC 40 25 28 21 28 30 172
Westport FD 1 7 7 5 18 9 47
Westport PD 126 124 147 160 237 232 1,026
Wethersfield PD 100 108 86 69 101 100 564
Willimantic FD 21 11 26 22 18 31 129
Wilton PD 118 112 82 50 50 59 471
Windsor Locks PD 34 23 20 14 29 38 158
Windsor PD 92 87 81 100 111 471
Winsted PD 26 41 27 36 47 32 209
Wolcott PD 37 36 41 27 43 37 221
Woodbridge PD 42 42 50 48 47 47 276
102,169 89,863 99,352 98,226 109,867 113,802 613,279
PSAP NAME Wireline Wireline Wireline Wireline Wireline Wireline 6 month
Call Volume 2002 Jan Feb March April May June TOTAL
Ansonia PD 442 376 398 396 398 445 2,455
Avon PD 205 234 354 445 488 588 2,314
Berlin PD 317 279 340 408 448 442 2,234
Bethel PD 283 267 347 330 353 374 1,954
Bloomfield PD 675 639 807 912 1,067 1,117 5,217
Branford PD 648 586 647 700 865 835 4,281
Bridgeport FD 8,106 7,244 8,060 8,540 9,331 10,175 51,456
Bridgeport PD 2,334 1,935 2,021 2,094 2,524 2,385 13,293
7
Bristol PD 1,224 1,077 1,654 2,060 2,157 2,395 10,567
Brookfield PD 261 235 312 511 656 663 2,638
Canton PD 96 94 208 190 192 235 1,015
Cheshire PD 466 376 485 614 701 727 3,369
Clinton ECC 196 168 166 186 200 193 1,109
Colchester EC 707 557 622 597 717 701 3,901
Cromwell PD 237 214 302 277 246 286 1,562
Danbury FD 1,938 1,673 1,977 2,152 2,358 2,270 12,368
Danbury PD 495 406 595 598 672 707 3,473
Darien PD 406 400 414 456 451 524 2,651
Deep River ECC 226 171 173 199 247 212 1,228
Derby PD 281 293 312 267 389 354 1,896
East Hartford PD 1,282 1,261 1,516 1,497 1,600 1,688 8,844
East Haven FD 682 639 710 847 743 803 4,424
East Lyme ECC 1,547 1,404 1,699 1,789 2,024 2,242 10,705
East Windsor PD 231 214 269 321 356 369 1,760
Easton PD 116 97 112 116 120 117 678
Enfield PD 678 600 783 881 837 920 4,699
Fairfield ECC 1,206 1,196 1,259 1,302 1,432 1,348 7,743
Farmington PD 401 357 527 798 896 844 3,823
Glastonbury PD 371 335 471 562 536 505 2,780
Granby PD 196 178 542 349 475 449 2,189
Greenwich PD 1,710 1,511 1,692 1,890 1,880 2,211 10,894
Groton ECC 1,010 856 1,074 1,133 1,220 1,337 6,630
Guilford ECC 435 352 399 382 419 438 2,425
Hamden ECC 1,427 1,205 1,341 1,556 1,657 1,586 8,772
Hartford PD 9,137 8,779 10,549 11,019 13,190 12,382 65,056
Ledyard ECC 257 216 1,357 1,212 436 518 3,996
Litchfield LCD 842 733 781 883 870 944 5,053
Madison PD 271 247 277 245 280 307 1,627
Manchester PD 1,210 1,080 1,278 1,347 1,380 1,489 7,784
Meriden PD 1,352 1,200 1,428 1,578 1,683 1,837 9,078
Middlebury PD 110 108 118 154 158 193 841
8
Middletown FD 6,284 4,695 1,356 1,421 1,455 1,389 16,600
Milford FD 1,116 992 1,136 1,144 1,281 1,301 6,970
Monroe PD 277 230 340 482 520 583 2,432
Montville ECC 1,105 967 1,096 1,196 1,407 1,227 6,998
Naugatuck PD 559 473 528 530 555 568 3,213
New Britain ERC 2,501 2,283 2,677 2,849 3,145 3,214 16,669
New Canaan PD 346 295 305 334 348 364 1,992
New Fairfield PD 149 154 211 193 220 224 1,151
New Haven ECC 6,269 5,552 6,626 7,168 7,820 7,970 41,405
New London PD 1,104 972 2,495 3,537 3,643 3,638 15,389
New Milford PD 350 320 437 497 559 624 2,787
Newington PD 678 637 725 1,053 1,178 1,056 5,327
Newtown PD 405 337 415 406 514 439 2,516
North Branford PD 181 138 199 209 236 291 1,254
North Haven PD 507 443 458 493 496 575 2,972
Northwest CT PS 627 508 599 617 666 709 3,726
Norwalk PD 2,548 2,299 2,383 2,525 2,656 2,640 15,051
Norwich PD 1,072 1,040 1,042 1,251 1,332 1,296 7,033
Old Saybrook PD 230 160 203 196 188 218 1,195
Orange PD 270 209 309 325 342 369 1,824
Plainville PD 422 366 492 483 603 612 2,978
Plymouth EC 176 200 283 278 270 397 1,604
Putnam PD 190 198 166 230 220 257 1,261
Quinebaug ECC 1,586 1,293 1,469 1,409 1,505 1,648 8,910
Redding PD 98 98 145 175 192 187 895
Ridgefield PD 490 408 547 643 691 713 3,492
Rocky Hill PD 333 314 376 460 467 513 2,463
Seymour PD 246 215 235 238 264 258 1,456
Shelton PD 806 667 722 800 855 931 4,781
Simsbury PD 307 280 353 366 405 464 2,175
South Windsor 340 309 346 404 485 436 2,320
Southbury PD 331 284 321 280 339 350 1,905
South Cent Reg ECC 508 392 444 484 501 497 2,826
9
Southington PD 689 622 729 762 880 823 4,505
Stamford PD 4,713 4,383 4,735 4,634 4,999 5,118 28,582
State Police Trp "A" 128 134 152 220 263 274 1,171
State Police Trp "B" 176 117 144 136 145 164 882
State Police Trp "C" 257 241 306 293 318 403 1,818
State Police Trp "D" 280 240 277 320 290 337 1,744
State Police Trp "E" 449 369 438 549 616 653 3,074
State Police Trp "F" 135 95 130 121 109 148 738
State Police Trp "G" 204 167 247 357 402 550 1,927
State police Trp "H" 197 230 499 684 733 569 2,912
State Police Trp "I" 129 142 211 341 413 414 1,650
State Police Trp "K" 254 216 269 312 326 317 1,694
State Police Trp "L" 279 215 213 264 312 315 1,598
State Police Trp "W" 526 540 504 479 472 491 3,012
Stonington PD 313 273 348 430 547 589 2,500
Stratford PD 1,238 1,144 1,242 1,386 1,579 1,526 8,115
Suffield PD 169 156 210 217 198 223 1,173
Thomaston PD 93 70 96 112 92 115 578
Tolland County MAD 1,188 1,160 1,318 1,434 1,593 1,431 8,124
Torrington PD 788 679 720 708 782 852 4,529
Trumbull PD 726 661 636 758 949 836 4,566
UCONN PD 261 403 468 636 359 296 2,423
Valley Shore EC 677 542 599 620 754 793 3,985
Vernon PD 509 438 546 554 550 593 3,190
Wallingford FD 640 605 747 862 956 985 4,795
Waterbury PD 4,316 3,799 3,972 3,998 4,352 4,788 25,225
Waterford ECC 407 367 489 609 677 692 3,241
Watertown PD 308 304 315 422 403 398 2,150
West Hartford PD 1,269 991 1,345 1,646 1,683 1,747 8,681
West Haven ERS 1,852 1,712 1,909 1,999 2,211 2,361 12,044
Weston ECC 236 169 162 253 273 286 1,379
Westport FD 32 20 46 15 44 36 193
Westport PD 632 556 642 589 712 724 3,855
10
Wethersfield PD 539 456 593 693 687 694 3,662
Willimantic FD 1,667 1,503 1,591 1,616 1,801 1,694 9,872
Wilton PD 329 264 351 456 509 553 2,462
Windsor Locks PD 249 205 256 253 314 310 1,587
Windsor PD 492 722 542 654 688 705 3,803
Winsted PD 183 177 203 191 221 222 1,197
Wolcott PD 214 182 187 204 181 171 1,139
Woodbridge PD 148 116 178 161 180 153 936
104,316 92,905 106,380 115,417 125,583 128,462 673,063
11
ATTACHMENT 5
Infoline: TOP 30 Service Categories
Town(s): Statewide
Selected: All Services
Gender: Both Age: All
Period: 01/01/2001 to 12/31/2001 Report Date:
Total number of Transactions : 223,608 09/09/2002
Total number of Service Requests: Page 1o1
315,782 f
Utility Assistance 26869
Substance Abuse Services 21906
Housing 16014
Legal Services 14527
Helpline Counseling 11856
Emergency Shelter 10918
Outpatient Mental Health Care/Counseling 10299
Food 9046
Health Insurance 8922
Health and Human Services Information 7872
Housing Payment Assistance 7396
Legal Education/Information 7060
Temporary Financial Aid 7052
Information Services 6832
Government Income 6525
Programs
Crisis Intervention 5674
Holiday Assistance 4739
Transportation 4715
Donor Services 4594
Consumer Assistance And Protection 4399
Personal/Household Goods 4392
Family Support Services 4095
Health Care Referrals 3526
Domestic Violence Services 3445
Psychiatric Support Services 3062
Mental Health Support 2892
Services
Outpatient Health Care 2730
Health Supportive Services 2727
Volunteer Opportunities 2697
WIC 2664
Infoline: All Service Categories
Town(s): Statewide
Selected: All Services
Gender: Both Age: All
Period: 01/01/2000 to 12/31/2000 Report Date:
Total number of Transactions : 204,572 09/09/2002
Total number of Service Requests: Page 1o3
273,386 f
Utility Assistance 27652
Substance Abuse Services 16959
Housing 11514
Legal Services 10499
Helpline Counseling 10364
Outpatient Mental Health Care/Counseling 8576
Emergency Shelter 8252
Information Services 8241
Food 7563
Health Insurance 6906
Temporary Financial Aid 6610
Health and Human Services Information 6161
Government Income 6103
Programs
Legal Education/Information 6090
Housing Payment Assistance 5547
Crisis Intervention 4697
Transportation 4442
Family Support Services 4200
Consumer Assistance And Protection 3832
Personal/Household Goods 3358
Domestic Violence Services 3241
Mental Health Support 3066
Services
Donor Services 2790
Health Care Referrals 2527
Health Supportive Services 2521
Holiday Assistance 2467
Medical Expense Assistance 2466
Volunteer Opportunities 2212
Psychiatric Support Services 2198
Outpatient Health Care 2157
Disease/Disability Information 2087
Specialized Health Care 1930
Employment Acquisition 1857
WIC 1833
Courts 1677
Case Management 1554
Administrative Entities 1483
Law Enforcement Agencies 1467
Home Improvement 1330
Social Insurance Programs 1329
Adult Education/ Enrichment 1315
Infoline: All Service 09/09/2002
Categories
Town(s): Statewide Page 2o3
f
Animal Services 1313
Criminal Justice System 1272
Consumer Regulation 1272
Health Assessment/ Diagnostic Services 1255
Records/Licenses/Permits 1247
Money Management 1214
Recreational/Leisure Activities 1204
Advocacy 1160
Human Rights Groups 1140
Employment Preparation 1106
Medical Technology Services 1096
Family Planning 1080
Children's Protective Services 1043
Tourism/Business/Industry 1039
Outreach Programs 1016
Law Enforcement Services 981
Political/Government 967
Information
Education 931
Occupational/Professional Associations 896
Dental Care 830
Adult Protective Services 793
Utilities Connection/Repair 767
Meals 761
Mental Health Facilities 756
Licensing/Certification/Accredi 722
tation
Municipal/Social Services 710
Maternal and Infant Care 670
Educational Programs 651
Immigration/Naturalization 639
Services
2
Health Education 623
Hospitals 620
Residential Facilities 610
In-Home Assistance 605
Public Safety 604
Disabilities Services 598
Child Care 559
Public Employment and Training Programs 544
Abused Persons Services 532
Community Action Groups 532
Mentoring 516
Libraries 497
Vocational Rehabilitation 476
Research/Planning 398
Companionship 389
Community Centers 381
Public Health 375
Smoking Education and 368
Prevention
Infoline: All Service 09/09/2002
Categories
Town(s): Statewide Page 3o3
f
Youth Development 360
Rehabilitation 320
Assisted Living Facilities 300
Nursing Home Care 299
Tutorial Services 281
Children's Health Services 267
Interpretation/Translation 266
Adoption 260
Foster Care 247
Environmental Improvement 243
Group Homes 238
Personal Emergency Response Systems 226
Transitional Mental Health 215
Services
Judicial Services 214
Gambling Help Services 207
Adult Day Care 195
Special Education 181
Technical Assistance 173
Early Childhood Education 150
Charities/Foundations/Funding Organizations 134
3
Employment Services 121
Direct Mail Refusal Request 91
Forms
Personal Reassurance 61
Services
Teen Pregnancy Prevention 40
Spiritual Enrichment 28
Sex Education 28
Audio Recording Services 28
Utility Disconnection 16
Notification
Employee Assistance 16
Programs
Community Groups 15
Computers 15
Peer Review Organizations 15
EPSDT 3
4